What is RoHS?
RoHS is the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment.
The RoHS Directive bans the placing on the EU market of new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants.
At first evaluation, many leather suppliers may consider that these regulations have no impact on the leather industry. However, there are some products that need to be considered, ie watches with leather straps, mobile phones with leather cases, children’s training shoes containing light components within the sole and numerous other examples.
Compliance
Manufacturers need to understand the requirements of the RoHS Directive in order to ensure that their products and components comply with the regulations. They must be able to demonstrate compliance by submitting technical documentation or other information to the enforcing authority on request and retain such documentation for a period of four years after the electrical and electronic equipment (EEE) is placed on the market. Enforcement authorities will carry out market surveillance to detect non-compliant products and may carry out tests for this purpose.
Testing
Testing for RoHS compliance is a complex issue due to the many different substrates and the various exclusions to the regulations.
IEC 62321:2008 is an International Standard, which specifies the determination of the levels of lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr(VI)) contained in inorganic and organic compounds, and two types of brominated flame retardants, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) contained in electrotechnical products.
It is left to the individual laboratories to determine the most appropriate procedures for the substrates being evaluated.
RoHS Recast
The recast RoHS Directive 2011/65/EU has repealed Directive 2002/95/EC. The recast Directive now draws its scope from the categories laid out in Annex 1 of the Directive as opposed to Annex 1a of the Waste Electrical and Electronic Equipment (WEEE) Directive.
Originally transposed into UK law under statutory instrument 2008 No. 37 and amended by statutory instrument 2009 No. 581 the recast directive will be transposed into UK law with a new statutory instrument which will be published October/November 2012 and enter into force on 2 January 2013.
BLC can offer advice and support with regard to testing samples and compliance. For further information contact info@blcleathertech.com
BLC members receive a 30% discount on all testing and problem solving services.
