RoHS: Frequently Asked Questions (Updated 10/3/06)
Promoting awareness toward perserving environments as well as complimenting healthy lifestyles has always been paramount to Creative Stage Lighting.
When we first introduced Dura-Flex™ cable in 1998 we did so without the inclusion of Talc as a slipping agent, as it is our belief that talc is a form/type of irritant. As soon as we learned about the RoHS initiative we immediately sought solutions to its compliance. In 2004 all Dura-Flex™ products became RoHS compliant.
To help inform our clients about RoHS we have answered these commonly asked questions.
We will continue improving our products based on our core values and forward thinking like the RoHS directive.
- What is RoHS?
- Why is this FAQ based on the EU RoHS Directive?
- If this is a European Union directive, why should I be concerned?
- Are Dura-Flex cable products RoHS compliant?
- Why was EU RoHS established?
- What is meant by the word "directive?"
- What is the "lead free directive?"
- What substances are on the EU directive list?
- Why are the 6 substances listed in the EU directive being restricted?
- What is meant by restricted?
- What are PBB and PBDE?
- What type of products are effected by EU RohS?
- Will it be illegal in EU to sell new items that aren't EU RoHS compliant?
- Does the EU RoHS directive apply to spare parts installed on new equipment?
- Does the EU RoHS directive apply to spare parts installed on used equipment?
- Does the EU RoHS directive apply to products made for own use?
- Can I import non-compliant products for own use?
- What is meant by "own use?"
- Does the EU RoHS directive apply to products for professional use as well as consumer products?
- Does the EU RoHS directive apply to batteries?
- What does "put on the market" mean?
- Does packaging for a product have to comply with the EU RoHS also?
- What is UL RoHS?
- What is WEEE?
- How do you pronounce RoHS?
Restriction of Hazardous Substances. A 2003 European Union (EU) directive that restricts the use of 6 hazardous substances in manufacturing electrical, and electronic equipment. It went into effect on July 1, 2006. The RoHS directive applies to products in the EU, whether made within the EU or imported. A copy of the directive can be found here: EU RoHS (PDF link).
Why Is This FAQ Based On the EU RoHS Directive?
The EU RoHS directive is what most legistlation in effect and pending is currently being compared to.
If this is a European Union directive, why should I be concerned?
Although the European Union directive has gotten the most attention, the USA and most industrialized nations are implementing the same restrictions. In the United States: There is a patchwork of state laws already in effect, and many more still pending. "California RoHS" or AB2202 (PDF link) which will take effect on January 1, 2007 is the first regulation in the USA modeled after EU RoHS.
States with laws in already in place include Connecticut, Florida, Hawaii, Iowa, Illinois, Maryland, Maine, Michigan, Minnesota, New Hampshire, New Mexico, New York, Oregon, Rhode Island, Virginia, Vermont, and Washington.
States with laws pending include California, Colorado, Connecticut, Florida, Hawaii, Illinois, Indiana, Louisiana, Massachusetts, Michigan, Minnesota, Montana, North Carolina, Nebraska, New Hampshire, New Jersey, New Mexico, Nevada, New York, Ohio, Oregon, Rhode Island, South Carolina, Tennessee, Texas, Virginia, Vermont, Washington and Wisconsin.
While EU RoHS covers six substances under one directive, many US states have separate laws pending or in effect for each substance. That is why some states may have existing laws and pending laws simultaneously.
Around The World: Japan has green procurement practices (JPSSI) in effect, that are even more stringent that EU RoHS. China, Korea, Canada, Taiwan and Australia have either legislation in effect or pending.
Are Dura-Flex™ cable products RoHS compliant?
Yes. Since 2004 all Dura-Flex cables have been manufactured in an ISO9001:2000 facility to comply with the EU RoHS directive now in place.
RoHS, along with the closely related European directive "waste electrical and electronic equipment" WEEE was established to help eliminate waste and health problems caused by the disposal of electronic equipment, also referred to as "e-waste". RoHS is concerned with materials entering the market, while WEEE is concerned with the disposal of these materials.
What is meant by the word "directive?"
Each European Union member state will adopt its own policies and enforcement using the directive as a guide. This may result in many different laws in the EU states.
What is the "Lead Free Directive"?
This is a commonly used name for the RoHS directive.
What substances are on the EU Directive List?
- Lead (Pb)
- Mercury (Hg)
- Cadmium (Cd)
- Chromium VI (CrVI) (also known as hexavelnt chromium or Cr6+)
- Polybrominated Biphenyls (PBB)
- Polybrominated diphenyl Ethers (PBDE)
Links are to toxicological profiles from the US Department of Health and Human Services Agency for Toxic Substances.
Why are the 6 substances listed in the EU directive being restricted?
They are common manufacturing substances that have conclusively been shown to be harmful to human health and the environment.
EU RoHS specifies maximum concentration values (MCVs) by weight and for each substance. They are not being completely eliminated. Below are the allowable amounts of each substance.
- Lead - 0.1%
- Mercury - 0.1%
- Cadmium - 0.01%
- Chromium - 0.1%
- PBB - 0.1%
- PBDE - 0.1%
Polybrominated biphenyls (PBB) and Polybrominated diphenyl ethers (PBDE) are flame retardants used in some plastics.
What type of products are Effected by EU RoHS?
- Household appliances
- IT and telecommunications equipment
- Consumer equipment
- Lighting
- Electrical and electronic tools (except large-scale stationary industrial tools).
- Toys, leisure and sports equipment
- Automatic dispensers
RoHS Article 3.(a) states that RoHS covers electrical and electronic equipment "which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out in Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current".
Will it be illegal in EU to sell new items that aren't EU RoHS compliant?
The laws will vary from country to country, as will the dates that they go into effect, but it is illegal in the EU to sell non-compliant items put on the market after July 1st, 2006.
Does the EU RoHS Directive apply to spare parts installed on new equipment?
Yes, the Directive does apply to spare parts for the repair, or reuse, of electrical and electronic equipment put on the market after 1 July 2006. This also includes spare parts that were put in stock before 1 July 2006, that may be used at a later date.
Does the EU RoHS directive apply to spare parts installed in used equipment?
Maybe, the Directive does not apply to spare parts for the repair, or reuse, of electrical and electronic equipment put on the market before 1 July 2006 (Article 2(3)). This is to insure that older electrical equipment can be maintained and reused. If the product was put on the market after 1 July 06, then RoHS would apply to spare parts for that product.
Does the EU RoHS Directive apply to products made for own use?
No, this only applies to products to be sold. However, if an item made for own use is sold, then RoHS does apply.
Can I import non-compliant products for own use?
No. It is a product that has been put on the market by the manufacturer, and therefore must comply with the current directive.
Own use is where a product has been built by an individual or company for use by that individual or company, not intended to be sold.
Does the EU RoHS directive apply to products for professional use as well as consumer products?
Yes. Both categories of products are covered.
Does the EU RoHS directive apply to batteries?
No, it does not apply to Lead-acid, Mercury and NiCD batteries even though they contain substances on the RoHS list.
What does "Put on the market" mean?
The words "put on the market" in Article 4 (1) of the RoHS Directive refer to the initial action of making a product available for the first time on the Community market. This takes place when the product is transferred from the producer to a distributor or final consumer or user on the Community market. "Making a product available for the first time" refers to each individual piece of equipment put on the market after the date for the substances restrictions (that is 1 July 2006), and not to the launch of a new product or product line. Moreover the concept of putting on the market refers to each individual product, not to a type of product, irrespective of whether it was manufactured as an individual unit or a series.
Does packaging for a product have to comply with the EU RoHS also?
Any packaging that is discarded after the product purchase is not covered by RoHS at this time.
A RoHS certification program offered by UL.
Waste Electrical and Electronic Equipment Directive. While RoHS deals with new products entering the market, WEEE deals with the disposal products at the end of their useful life. If a product is RoHS compliant, it should by default also be WEEE compliant.
A copy of the directive can be found here: EU WEEE (PDF link) .
California's version of WEEE - the Electronic Waste Recycling Act SB20/50.
As "roze" or "rose".
Creative Stage Lighting Co, Inc.
P.O. Box 567
149 Route 28N
North Creek, NY 12853
Phone: (518) 251-3302
Fax: (518) 251-2908
info@creativestagelighting.com