In terms of compliance requirements for selling electrical and electronic products to EU, we explain some EU product safety regulations in detail for sellers. What preparations should be made before products are put on the EU market? What are the serious risk issues that most sellers might have overlooked?
What is RoHS?
RoHS is the basis for selling electrical and electronic products to EU.
RoHS stands for Restriction of Hazardous Substances, also known as Directive 2002/95/EC, which originated in the European Union and restricts the use of certain hazardous substances found in electrical and electronic products (called EEE). Since July 1, 2006, all products applicable on the EU market must pass RoHS certification.
Scope of RoHS applicable products
1) Large household appliances: refrigerators, washing machines, stoves, air conditioners;
2) Small household appliances: vacuum cleaner, hair dryer, coffee maker, iron;
3) Computing and communication equipment: computers, printers, photocopiers, telephones;
4) Consumer electronic products: TVs, DVD players, stereo speakers, cameras;
5) Lighting: lamps, lighting equipment, bulbs;
6) Power tools: drill, saw, nail gun, sprayer, lathe, trimmer, blower;
7) Toys and sports equipment: electronic game toys, electric trains, treadmills;
8) Automatic teller machine: vending machine, automatic teller machine.
The following product categories are not applicable to the RoHS
1) Equipment with specific military use;
2) Space equipment;
3) Equipment specially designed as part of another type of equipment outside the scope of this directive, and only when the equipment belongs to this equipment and can only be replaced by specially designed equipment can perform its functions;
4) Large fixed industrial tools;
5) Means of transportation for people or goods, except for electric two-wheeled vehicles that have not been type-approved;
6) Active implantable medical equipment;
7) Large fixed device;
8) Photovoltaic panels, assisting public, commercial, industrial and residential applications to produce solar energy;
9) Equipment designed for research and development, etc.
Scope of materials restricted by RoHS
RoHS 1 stipulates the maximum content of the following six restricted materials:
- Cadmium (Cd) <100 ppm
- Mercury (Hg) <100 ppm
- Lead (Pb) <1000 ppm
- Polybrominated biphenyls (PBB) <1000 ppm
- Polybrominated diphenyl ether (PBDE) <1000 ppm
- Hexavalent chromium (CrVI) <1000 ppm
In 2011, the European Union issued the 2011/65/EU Directive, namely RoHS 2.
RoHS 2 contains the CE marking directive, which means that RoHS compliance now applies to products that currently require CE marking.
RoHS adds category 8 (medical equipment) and category 9 (control and monitoring instruments) with additional compliance to keep records.
In 2015, the Directive 2011/65/EU (RoHS 2) was revised into Directive (EU) 2015/863, called RoHS 3. Four substances were added to the current six restricted substances (cadmium, mercury, lead, polybrominated biphenyls, polybrominated diphenyl ethers, six Valence chromium).
The restriction took effect on July 22, 2019, for all electrical and electronic equipment except for categories 8 and 9. The category 8 and category 9 restrictions will take effect on July 22, 2021.
RoHS 3 aims to help and protect the environment and residents from known harmful substances in electronic and electrical equipment.
The other 4 substances stipulated by RoHS 3 and their allowable maximum limits are:
- Bis (2-ethylhexyl) phthalate (DEHP) <1000 ppm
- Benzyl butyl phthalate (BBP) <1000 ppm
- Dibutyl phthalate (DBP) <1000 ppm
- Diisobutyl phthalate (DIBP) <1000 ppm
Is it compulsory to affix the EU RoHS mark on the outer packaging of the product?
The RoHS (Restriction of Hazardous Substances) mark is a voluntary mark and is provided voluntarily; the RoHS mark can help companies greatly reduce the financial and management burden of RoHS compliance.
Although the RoHS mark is a single product certification, it can be extended to product series, provided that the series uses the same raw materials, similar management systems and basic designs have not changed significantly.
What other preparations do sellers need to make?
1. Affix the CE mark
According to the RoHS directive (2011/65/EU), the CE mark should be affixed before electronic and electrical equipment (EEE) is placed on the EU market; the CE mark should be clearly visible, legible, and permanently affixed to the finished product or its nameplate. If it is not possible or guaranteed to do so due to the nature of electrical and electronic equipment, it should be affixed to the packaging and accompanying documents.
2. Compliance with WEEE regulations
1) Register WEEE number
According to the requirements of the WEEE Directive (2012/19/EC), since August 13, 2005, manufacturers of electrical and electronic equipment circulating on the EU market must bear the responsibility of paying for the recycling of their own scrap products in a legal sense. The EU Member states are obliged to formulate their own recycling plans for electrical and electronic products and to establish relevant supporting recycling facilities so that end users of electrical and electronic products can dispose of scrapped equipment conveniently and free of charge.
Therefore, sellers need to register their WEEE number on the EU’s EAR system, and entrust a formal third-party electrical and electronic product recycling and processing agency to recycle and process waste electrical and electronic products.
2) Place WEEE logo
Product packaging, product manuals, and product labels are all printed with the WEEE recycling logo.
3. Appoint an EU authorized representative
According to the requirements of the EU Market Supervision Regulation EU2019/1020, some products sold in the EU (excluding the UK) need to ensure that they have EU responsible person in the EU before July 16, 2021 The manufacturer and his responsible person is responsible for product compliance.
4. Additionally affix the EC-REP label information
The manufacturer needs to ensure that the name and contact information of the EU authorized representative are listed on the product or product packaging. If products sold to the European Union do not contain this information, the goods may be intercepted at customs or unable to be delivered to the buyer.
In conclusion, after July 16, 2021, products from non-EU regions that want to be placed on the EU market will face numerous product compliance audits. Any ignorance of one of these requirements will seriously affect whether subsequent products will be admitted at EU customs.
Therefore, before importing and selling the product to EU, the non-EU seller must consult a professional EU representative service provider and compliance expert in advance, to understand the detailed EU product compliance policy and avoid greater losses.