Meaning of the RoHS electrical devices and electronic equipment in Germany and in the EU

On January 27th, 2003 the European Parliament and the Council published the directive 2002/95/EC for limitation of use of certain hazardous substances in electrical devices and electronic equipment. This directive which is applicable within the European Union was implemented in national law in the member states and is named in summary RoHS (Restriction of the use of certain hazardous substances). In Germany, the Electrical and Electronic Equipment Act which was issued on March 16th, 2005 includes the WEEE directive as well as the RoHS directive.

The ROHS of the Electrical and Electronic Equipment Act is now governed by its proper regulation

The German Federal Ministry for Environment Nature Conservation and Nuclear Safety (BMU) submitted us the draft of a "Regulation to limit the use of certain hazardous substances in electrical and electronic devices (Regulation for substances in electrical and electronic devices – ElektroStoffV)".

The most important points from our point of view in brief:
The ElektroStoffV (Regulation on substances in electrical and electronic devices) prohibits the placing of electrical devices and electronic devices (incl. spare parts, etc.) on the market which include more than 0.1 percent per weight of lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE) or more than 0.01 percent per weight of cadmium per homogeneous material.

The proof for this is submitted in form of an EU declaration of conformity related with a CE marking.

Manufacturers and importers shall place devices only on the market if these declarations of conformity are available.

Distributors have to check this with "due diligence" before placing such devices on the market.

This regulation will presumably come into force since it implements the EU directive 2011/65/EU. Only slight changes are to be expected. We will ask the BMU to explain the term "homogeneous material” in more detail.

You may rest assured that we will take all steps for you in order that you are able to provide the proofs without problems and publish when your products will comply with these specifications.
  
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