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Recycling electrical and electronic equipment (EEE) can have unintended consequences for the environment and human health. European Directive 2011/65/EU, RoHS (Restriction of Hazardous Substances in Electrical and Electronic Equipment), has been introduced to mitigate the negative effects of substances like lead, mercury, cadmium, chromium (VI), polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) that can be contained in EEEs.

From July 22, 2019 new restrictions on phthalates DEHP, BBP, DBP and DIBP will apply to all EEE (and their cables and spare parts) with the exception of medical devices and monitoring and control instruments, and their cables and spare parts. For that latter set of devices, these restrictions will apply from July 22, 2021.

UL’s subject matter experts Elisa Gavazza, Silvia Lai and Richard Smart answer some questions about the RoHS Directive from manufacturers, importers and distributors with products available in the EU market.

Q: The product I manufacture has an electronic component embedded in its main part. Do I need to assess the product as a whole?
A: Yes, if the component is permanently combined in the product. If any permanent component of a product relies on electricity, the entire product falls under the scope of RoHS. If the electrical component is supplied as part of a disassembled kit, RoHS applies only to that component and not the whole product.

Q: My product complies with RoHS. Do I still need to evaluate to REACH?
Yes. Whilst some aspects of RoHS (e.g. lead and cadmium) do address the REACH compliance, there are other substances that are not covered. Within RoHS there are some exemptions available, but these do not exempt the materials under REACH. As an example, metallic lead is permitted in RoHS as an exemption but may still trigger a REACH SVHC action.

Q: Can the lab advise on exemptions for RoHS?
A: The UL lab can highlight exemptions within the directive. However, as these are often linked to the functions and use of components, the manufacturer should provide the overview and declare the component/material exempt and why. Documentation to explain exemptions are crucial.

Q: Can I combine the RoHS Declaration of Conformity with other EU DOCs?
A: Yes, you can combine multiple directives within one DOC.


To learn more about the important changes regulating the presence of dangerous substances in electrical and electronic equipment in Europe starting July 22, 2019, watch our complimentary WEBINAR or contact us for more information about how UL can support your business.

Elisa Gavazza, UL Global Toy Principal, supports UL in the toy technical area with more than 15 years of experience in the industry. She participates in many international working groups (ISO TC 181, CEN TC 52, ASTM F15.22, European Notified Body co-ordination group), anticipating the needs of toy manufacturers and retailers. She has a wide knowledge of legislation and regulatory requirements applicable to toys at worldwide level and works with both manufacturers and enforcement authorities. She has also been a training provider and speaker in private and public training sessions. 

Silvia Lai, Consumer Supervisor — Regulatory Research & Protocol Development, has more than 10 years of experience in regulatory research, product testing and certification. She is part of the Global Regulatory Affairs Team in UL’s Consumer and Retail Services, managing the EMEA Region. Silvia is focused on regulatory and technical updates related to the identification and interpretation of the regulatory obligations that may affect companies, particularly chemical restrictions and duties that apply to consumer articles (including toys, childcare articles, textile/leather articles and jewelry). Silvia holds a Master’s degree in environmental sciences (Milan University). 

Richard Smart, Toy Key Account Manager, supports the global and other key accounts within UL with programme management and technical support. He has more than 24 years experience in the toy and consumer product field, working for test laboratories and retailers, and brings experience of the wider supply chain. Richard provides training services for UK-based clients on a range of subjects and is a regular presenter at UL’s consumer seminars in the UK.


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