On 18.11.2021, the European standard DIN EN 50581:2012 expired and was replaced with the harmonized standard EN IEC 63000:2018. This supports the RoHS Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (with exemptions) with immediate effect. Even though the content of this standard remains largely unchanged from its predecessor, every manufacturer must now convert their CE declarations of conformity to EN IEC 63000:2018 and refer to it. This affects all products that are covered by the RoHS Directive and thus require mandatory CE marking. According to the FBDi Association, it is worth mentioning in this context that a declaration of conformity lists all directives applicable to the respective product, including, for example, those for EMC, low voltage and eco-design.
The underlying objective is to further harmonize legislation for even more countries in order to ensure uniform assessment. It defines the technical documentation that a manufacturer must prepare for the assessment of electrical and electronic equipment with regard to the restriction of hazardous substances in order to declare compliance with the applicable substance restrictions concerning RoHS Directive 2011/65/EU. For this purpose, the IEC 63000 standard describes the transfer of necessary technical ingredient declarations within the supply chain. Like its predecessor (EN 50581:2012), it is recognized by the industry and the enforcing authorities and represents the state of the art. The test steps described (e.g. evaluation of material + supplier) are also helpful in demonstrating compliance with other requirements of regulations including REACH (EC) No. 1907/2006 and POP- (EU) 2019/1021.
RoHS Exemptions Review
Currently, many companies are waiting for information on the extension of various exemptions that expired on July 21, 2021, such as exemption 6c (lead in copper alloys). Because applications for the extension of the exemption were submitted in due time, among others also by the international association (‘RoHS Umbrella Industry Project’), the exemptions will remain in place until the EU Commission has completed its assessment and announced a decision. An important factor in the decision is the report by Öko-Institut e.V., which examines the scope and necessity of the exemption extension. “Even if a date is communicated there before the end of the year, we assume that a decision will not be made until the beginning of 2022,” says Patrick Lehn, management systems officer at Rutronik and member of the RoHS Competence Circle within the environment & compliance team of the FBDi association.
The Commission itself refers to the high number of applications on hand and the processing time of 24 months from the submission of the application. “In concrete terms, this means that until the EU Commission has decided on an application for renewal, this exemption will remain valid unchanged. Nevertheless, manufacturers should start looking for alternatives today, if that has not already started.” Experience shows that every exemption renewal includes restrictions up to and including ultimate rejection, as the EU Commission is pursuing with the RoHS Directive.