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RoHS Directive – 2002/95/EC (and its amendments) – EU Directive on the restriction of the use of certain hazardous substances (RoHS) in electrical and electronic equipment


All the materials (whether accessible or not), apart from those exempt in the Directive, of electrical and electronic products (that fall into the scope) should comply with the requirements of the RoHS Directive. The following summarizes the substances to be determined and the corresponding limits.



Requirements of the Directive


4 types of Heavy metals:   

                                                                                  Limit (in homogeneous materials*)

-         lead,                                                           0.1% by weight

-         mecury,                                                       0.1% by weight

-         cadmium,                                                    0.01% by weight

-         hexavalent chromium                                    0.1% by weight


2 types of Brominated flame retardants:

                                                                                 Limit (in homogeneous materials*)

-         polybrominated biphenyls (PBB)                    0.1% by weight

-         polybrominated diphenyl ethers (PBDE)          0.1% by weight



Scope of the Directive


The Directive applies to the following electrical and electronic equipment (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 (with the exception of large-scale stationary             industrial tools)

7. Toys, leisure and sports equipment

8. Automatic dispensers

9. Electric light bulbs

10.Luminaires in households

**EEE in this Directive are defined as those designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current



Test Methods



Test Method



Cadmium (Cd) Content

Metal: As per Section 12, page 70 / US EPA 3050B by acid digestion and determination by ICP-AES; or

Plastic: As per Section 11, page 61 / US EPA 3051A by acid digestion and determination by ICP-AES; or

Screening by Energy Dispersive X-ray Fluorescence Spectrometry (EDXRF)

Lead (Pb) Content

Metal: As per Section 12, page 70 / US EPA 3050B by acid digestion and determination by ICP-AES; or

Plastic: As per Section 11, page 61 / US EPA 3051A by acid digestion and determination by ICP-AES; or

Screening by Energy Dispersive X-ray Fluorescence Spectrometry (EDXRF)

Mercury (Hg) Content

As per Section 10, page 53 / US EPA 3050B or EPA 3051A by acid digestion and determination by ICP-AES; or

Screening by Energy Dispersive X-ray Fluorescence Spectrometry (EDXRF)

Chromium (VI) (Cr6+) Content

Metal: With reference to BS EN ISO 3613:2001 incorporating corrigendum No. 1, “Chromate conversion coatings on zinc, cadmium, aluminum-zinc alloys and zinc aluminum alloys – Test Methods”; or

Plastic & Electronics:  As per Section 9, page 48 / US EPA 3060A by alkaline digestion and determination by UV-VIS spectrophotometer; or

Screening by Energy Dispersive X-ray Fluorescence Spectrometry (EDXRF)

Polybrominated Biphenyls (PBB) & Polybrominated Diphenyl Ethers (PBDE)

As per US EPA 3540C by solvent extraction and determination by GC-MS and HPLC; or

Screening by Energy Dispersive X-ray Fluorescence Spectrometry (EDXRF)









































The Directive covers EEE where the basic (primary) function cannot be fulfilled when the electric current is off. If the electrical energy is used only for support or control functions this type of equipment is not covered by the Directive. Example for the latter is combustion engine with ignition, gas cooker with electric clock, etc. 

The Directive does not apply to batteries, which is covered by the Directive 98/101/EC

The substance ban under the Directive applies to the final product and not the production process.




Useful information


Information for lead-free solder


There are only a small number of lead-free solder alloys with a melting temperature between about 260oC and about 350oC. Examples are:

-         Bismuth-silver

-         Gold-tin

-         Gold-silicon

However, all of these are hard, brittle materials and so unsuitable for many of the applications where high melting temperature lead-based solders are currently used, while lead-based alloys have significantly different physical properties: lead solder with > 85% lead are ductile.


Substitutions of Lead-based Solder


Base Material

Melting Point ( oC)

Added Material




190 – 210

210 – 220

Bi (lower T)

Cu (Wettab.)

Zn, In

- Good for thermal

- Strong pull strength

- Good elongation

- High melting temperature

- Expensive (Sn-Pb x 2 to 3)

- Poor wettability


190 – 210

Ag, Cu, etc.

- Lower melting temp. is possible

- Strong pull strength

- Good Wettability

- Hard and fragile

- Difficult to machining

- Short thermal fatigue life


190 – 200

Bi (Wettab.)

Cu, Ag, In

- Same profile as Sn-Pb solder

- Low cost (Sn-Pb x 1.5)

- Strong pull strength

- Good elongation

- Short thermal fatigue life

- Poor wettability



(52% In)

Ag, etc.

- Lower melting temp. is possible

- Good elongation

- Expensive

- Small pull strength




Explanation on homogeneous materials


*Homogeneous material means a material that cannot be mechanically disjointed into different materials.


- A plastic cover is a “homogeneous material”if it consists of one type of plastic that is not coated with other materials. In this case the limit values would apply to the plastic.

- An electric cable that consists of metal wires surrounded by non-metallic insulation materials is an example of “non-homogeneous material” because the different materials could be separated by mechanical processes. In this case the limit values of the Directive would apply to each of the separated materials individually.

- A semi-conductor package contains many homogeneous materials which include: plastic moulding material, tin-electroplating coatings on the lead frame, the lead frame alloy and gold-bonding wires.




Introduction to Polybrominated biphenyls (PBBs)


What are PBBs?


Polybrominated biphenyls (PBBs) are chemicals that were added to plastics used in a variety of consumer products, such as computer monitors, televisions, textiles, and plastic foams, to make them difficult to burn. Because PBBs were mixed into plastics rather than bound to them, they were able to leave the plastic and find their way into the environment.


What happens to PBBs when they enter the environment?


PBBs entered the air, water, and soil during their manufacture and use. In addition, animal feed was accidentally mixed with 500-1,000 pounds of PBBs in lower Michigan in 1973. This contamination of the food chain affected millions of farm animals and humans living in Michigan at this time. PBBs entered the environment during the disposal of contaminated animal feed and animal products during the agriculture contamination episode. PBBs also entered the environment from PBB-containing wastes that manufacturers disposed of in waste sites.


How can PBBs affect my health?


Much of what is known about the health effects of PBBs in people comes from studies of ingestion in Michigan in the early-to-mid 1970s, where feed for farm animals was accidentally contaminated with a fire retardant containing PBBs. People were exposed to PBBs for several months when they ate meat, milk, and eggs from the contaminated animals. After news of the contamination episode became widespread, many Michigan residents complained of various health problems, including nausea, abdominal pain, loss of appetite, joint pain, fatigue, and weakness. However, it could not be clearly established that any of the problems were caused by eating the food contaminated with PBBs. PBBs also did not cause any definite changes in the livers or immune systems of the Michigan residents. However, some people who ate the contaminated food developed skin disorders, such as acne and hair loss. It is likely that PBBs caused the skin problems because other chemicals similar to PBBs also cause these effects. Workers who were exposed to PBBs for a few days to months by breathing and skin contact also developed acne, although not all persons exposed to PBBs developed acne. Very little is known about the health of people who are exposed to low levels of PBBs for long periods by eating, breathing, or skin contact.




Introduction to polybrominated diphenyl ethers (PBDE)


What are PBDEs?


PBDEs are flame-retardant chemicals that are added to a variety of consumer products to make them difficult to burn. Because PBDEs are added rather than reacted to the product, they could leave the product under ideal conditions and enter the environment, but this rarely happens. There are three commercial PBDE products (i.e., penta-, octa-, and decabromodiphenyl ethers). Deca- and octa-brominated types of PBDEs are also produced in China and Israel. Its main use is for electronic enclosures, such as television cabinets. Octabromodiphenyl ether (octaBDE) product is used in plastics for business equipment. Pentabromodiphenyl ether (pentaBDE) product is used in foam for cushioning in upholstery. PBDEs have not been associated with actual health-related effects. Concerns have increased, however, because some of these chemicals (particularly the pentaBDEs) have been found in the environment at varying concentrations. Environmental concentrations of lower brominated PBDEs, which may be leveling off in Europe, appear to be increasing in certain areas of Canada and the United States.


What happens to PBDEs when they enter the environment?


PBDEs enter air, water, and soil during their manufacture and use in consumer products. When PBDEs are suspended in air, they can be present as particles. They eventually return to land or water as the dust settles and are washed out by snow and rainwater. It is not yet possible to say how long PBDEs remain in the air. PBDEs do not dissolve easily in water, and therefore, high levels of PBDEs are not found in water. The very small amounts of PBDEs that do occur in water stick to particles and eventually settle to the bottom. Sediments at the bottom of bodies of water, such as lakes and rivers, generally act as reservoirs for decaBDEs, which can remain there for years. Some lower brominated PBDEs (e.g., tetra- and penta-congeners of PBDE) in water may build up in fish to low concentrations (about 10 billionths of a gram to 1 millionth of a gram of PDBE per gram of fresh fish [or 10x10-9-1x10-6 grams of PBDE per gram of fresh fish]). However, higher brominated PBDEs, such as decaBDE, are not found in fish at measurable concentrations. In general, the breakdown of PBDEs in soil is very slow, so they may remain in soil for several years. PBDEs bind strongly to soil particles. Rainwater is not expected to spread them much below the soil surface; thus, it is unlikely that PBDEs will enter groundwater.


How can PBDEs affect my health?


Nothing definite is known about the health effects of PBDEs in people. Practically all of the available information is from studies of laboratory animals. Animal studies indicate that commercial decaBDE mixtures are generally much less toxic than the products containing lower brominated PBDEs. Because of its very different toxicity, decaBDE is expected to have relatively little effect on the health of humans. Rats and mice that ate food containing moderate amounts of lower brominated PBDEs for short periods of time had mainly thyroid effects. Rats and mice that ate smaller amounts over several weeks or months developed effects in the liver and in the thyroid. It is speculated that many of the thyroid effects of PBDEs are specific to the species of test animals, suggesting that they are less likely to occur in humans. Subtle behavioral changes have been observed in animals exposed to PBDEs as infants. One possible explanation for the behavioral effects might be related to changes in the thyroid, because development of the nervous system is dependent on thyroid hormones. PBDEs have not caused other kinds of birth defects in animals, but more studies are needed to determine if PBDEs can impair reproduction. Preliminary findings from short-term animal studies suggest that some PBDEs might impair the immune system. Animals exposed to PBDEs by skin contact showed signs of skin irritation only if they had been scratched.





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