RoHS compliance is a requirement for companies that sell products in European Union (EU) countries. An abbreviation for Restriction of Hazardous Substances, RoHS is an EU directive that restricts the use of a defined list of substances that harm human health and result in toxic waste. To avoid fines and penalties, buyers need to ask for a Certificate of Conformity (COC) which states that the product is RoHS compliant.

Certificates of Conformity (COCs), RoHS, and Rubber Products

Certificates of Conformity, or Certificates of Compliance, are inspected during EU customs clearance to determine whether the product that is being imported meets RoHS and other requirements. Typically, a COC contains the following information:

  • Product identification

  • List of all safety regulations that the product must meet

  • Importer or manufacturer identification

  • Contact information for the person maintaining records of test results

  • Date and place where the product was manufactured

  • Date and place where the product was tested for compliance

  • Identification of any third-party laboratory

RoHS covers electrical and electronic equipment (EEE) but is about more than just wires, cables, and relays. The rubber seals, gaskets, and insulation that are used with electrical and electronic enclosures also need to be made of RoHS compliant materials to ensure end-product conformity. Because RoHS is more than a single directive, buyers need to understand its scope as well as its evolving requirements.

Let’s take a look at RoHS 1, RoHS 2, and RoHS 3 and consider what you need to know.

RoHS 1 Compliance

The original RoHS standard, known as Directive 2002/95/EC, took effect on July 1, 2006 and restricted (but did not ban) the use of six hazardous substances found in many electrical and electronic products.

Here is a list of these six substances, along with their maximum allowable percentages.

  • Cadmium (0.01%)

  • Lead (0.1%)

  • Mercury (0.1%)

  • Hexavalent chromium (0.1%)

  • Polybrominated biphenyls (PBB) (0.1%)

  • Polybrominated diphenyl ethers (PBDE) (0.1%)

At first glance, some of these substances may seem far removed from rubber products. For example, the lead that’s used in solder helps to attach electronic components to printed circuit boards while forming an electrical connection. Yet lead can also be used in the production of various rubber materials. In fact, some of the worst cases of lead poisoning have involved rubber compounding or mixing.

Mercury, another toxic element, is used in switches and relays, common components in control panels for industrial machinery and equipment. Historically, mercury was also used to provide a strong red or brown color to rubber materials. Cadmium, a common ingredient in computer screens and printers, can be used as a pigment in black rubber.

As Annex 1 of Directive 2002/95/EC explains, RoHS 1 also established 11 categories of EEE.

  1. Large household appliances

  2. Small household appliances

  3. IT and telecommunications equipment

  4. Consumer equipment

  5. Lighting equipment

  6. Electrical and electronic tools

  7. Toys, leisure, and sports equipment

  8. Medical devices

  9. Monitoring and control instruments, including industrial

  10. Automatic dispensers

  11. Other EEE covered not covered by any of the categories above

Although RoHS 1 defined these categories, all of them did not take effect at once. Rather, RoHS categories are being phased-in over time. Several of them, as we will see, won’t take effect until next year.

Note: Depending on your industry, it may be important to know that Category 11 products include two-wheeled electric vehicles, electronic nicotine delivery systems, and cables with a working voltage of 240V.

RoHS 2 Compliance

RoHS2, also known as Directive 2011/65/EU, took effect on July 21, 2011. Like RoHS 1, this newer directive restricted the use of cadmium, lead, mercury, hexavalent chromium, PBB, and PBDE. For EEE manufacturers, RoHS2 also imposed important two new obligations. Specifically, EEE manufacturers were required to prepare EU declarations of conformity and to affix CE markings to finished products.

RoHS 2 also phased-in several more categories from the list in RoHS1. Annexes III and IV in Directive 2011/65/EU also defined exceptions. Military equipment, active implantable medical devices, photovoltaic panels, large-scale fixed installation, and large-scale industrial tools are all exempt from RoHS2. So are batteries and package materials since these items are subject to different EU directives.

RoHS 3 Compliance

RoHS3, or Directive 2015/863, added four more restricted substances to the list of six found in RoHS 1. These newly restricted ingredients are phthalates, chemicals that make rubber and plastic softer, but that are also linked to harmful effects on human health.

Here is a list of the four RoHS3 restricted substances along with allowable percentages.   

  • Bis(2-ethylhexyl) phthalate (DEHP) (0.1 %)

  • Butyl benzyl phthalate (BBP) (0.1 %)

  • Dibutyl phthalate (DBP) (0.1 %)

  • Diisobutyl phthalate (DIBP) (0.1 %)

All four of these phthalates impart flexibility and make materials harder to break. Some are also used in bonding or joining applications. For example, DEHP and DIBP are both used in industrial  adhesives. BBP is added to polyurethane adhesives as well to some polyurethane rubbers and acrylic-based polymers. DBP adds flexibility to rubber and is used in some films.

RoHS3 phased-in some new categories, but there are still two that have not yet taken affect.

  • Medical device (Category 8)

  • Monitoring and control instruments, including industrial (Category 9)

Important: If you make products in these categories, you have until July 22, 2021 to achieve compliance.

Risk Mitigation and Certificates of Conformance

If your company’s products contain banned substances, the EU won’t allow them as imports – and you could face fines and other penalties for trying. That’s why it’s important to buy rubber products from a company that sources materials from trusted suppliers and who can provide you with a RoHS COC for sponge and solid profiles, bulb trim, edge trim, window channels, sheeting, flooring, and much more.

Whether you need a distributor for rubber coils or a fabricator for finished gaskets, you can count on Elasto Proxy to help you comply with RoHS. Many of our extrusions come from Europe, and our manufacturing center near Montreal, Quebec, Canada can convert stock materials into custom solutions with technologies such as water jet cutting  and a choice of gasket bonding methods.

Do you need RoHS compliant rubber products? To request a quote or to discuss your application, please contact us.

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