Rave Computer provides a variety of electronic based computer equipment. These products are purchased from various vendors and integrated to meet specific customer requirements. Rave works closely with our vendors to ensure that we have a clear understanding of what products may or may not comply with the Restriction of Hazardous Substances (RoHS) Directives.
Rave consults with various customers as requested to inform them of RoHS directives, how their specific product/system requirements may be affected and what alternatives exist for their products.
RoHS-Compliant products are not always backward compatible with current products. Rave can provide you services that will help you manage RoHS directives.
RoHS Service Offerings:
- Review bill of materials for RoHS compliance
- Provide alternative material sources
- Report on part replacements and data sheets
- Search for replacement components
- Drop in replacements
Product Design Services:
- Redesign the product to be RoHS compliant
- Testing and verification of design changes
Pre-RoHS Product Repair Services:
- Enable long-term support options in pre-RoHS environments
Manage Mixed Product Services:
- Reverse logistics of repair parts
- Return RoHS parts to RoHS systems
For more information on RoHS, visit:
Objectives and Implementation of the RoHS Directive (2002/95/EC)
The Restriction of Hazardous Substances in Electrical and Electronic Equipment (ROHS)
Exclusion and Liability
The WEEE and RoHS Directives are complex and this information is for general information only. Affirmation of these Directives should have the approval of professional counsel. Rave Computer cannot accept responsibility for actions taken based on information on this site.
- What Does RoHS and WEEE Mean? - Some Basic Facts
- Does It RoHS and WEEE Apply to Your Product?
- What are the Products that are Outside the RoHS and WEEE Directives?
- What is required for Products under the WEEE Directive?
- What is required for Products under the RoHS Directive?
- How are RoHS and WEEE Monitored within the European Union?
- Information About Manufacturing And Inspection
What Does RoHS and WEEE Mean? - Some Basic Facts
These two European Directives directly affect producers of certain items of electrical and electronic equipment. It is the responsibility of the company placing the electrical or electronic equipment (EEE) onto the market (the producer) to decide if their products are within the scope of these Directives. The producer is defined as the manufacturer, distributor or importer of the equipment within the European Union. Both Directives list categories of end-user equipment, which are covered by, or exempt from the Directives.
The WEEE Directive - At a Glance
The WEEE Directive is an environmental legislation designed to reduce the amount of waste electrical and electronic equipment (WEEE) being dumped in landfill sites. It aims to make the producer (i.e. manufacturers) responsible for WEEE, encourage the recycling, and re-use of EEE at the end of its useful life. The WEEE Directive defines 10 categories of end-user equipment, which are covered by the Directive, and provides guidelines for recycling targets. This Directive became EU law on August 13 2005, however many Member States (including the UK) have not yet implemented national legislation or a practical system for handling the Directive.
The RoHS Directive - At a Glance
The RoHS Directive applies to end-user electrical and electronic equipment (EEEE) and sets maximum acceptable levels of 6 substances within the composition of the product - lead, cadmium, mercury, hexavalent chromium and both polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants. The main issue facing the electronics industry is the use of lead in the manufacture of components and circuit board assemblies. The RoHS Directive applies to 8 of the 10 product categories defined in the WEEE Directive (it does not apply to Monitoring and Control Equipment or Medical Devices).
Does It RoHS and WEEE Apply to Your Product?
Both Directives reference a list of product categories and exemptions to be considered by producers. The following information may help you decide whether your product falls within the scope of the Directives.
The two major types of equipment which fall outside the scope of both the WEEE and RoHS Directives are:
- Fixed Installation - This is defined by the European Commission Frequently Asked Questions document as, a combination of several items of equipment, systems, finished products and/or components assembled and/or erected by an assembler/installer at a given place to operate together in an expected environment to perform a specific task, but not intended to be placed onto the market as a single functional or commercial unit.
- Large-Scale Stationary Industrial Tool/Machine - This is an exclusion within product category 6 - electrical and electronic tools. It is defined by the European Commission Frequently Asked Questions document as, a machine or system, consisting of a combination of equipment, systems or products, each of which is designed to be used in industry only, permanently fixed and installed by professionals at a given place in an industrial machine or in an industrial building to perform a specific task. [The WEEE Directive excludes these items because it is not practical to identify a single responsible party for disposal and recycling. The RoHS Directive excludes them on the grounds of consistency with the WEEE Directive.]
- In addition to these, equipment described as monitoring and control equipment (such as industrial control panels and remote monitoring systems) and medical equipment (including analyzers, radiotherapy equipment & laboratory equipment) are categories defined in the WEEE Directive which are specifically excluded from the RoHS Directive. (Over the next few years, the EU will review the technical feasibility of including these categories within the Directive.)
Finally, equipment used for servers, storage/storage array and telecommunications infrastructure (switching, routers and gateways) is covered by the RoHS Directive but, may use lead in solder (the limits for the other 5 substances must comply). This exemption has been introduced to allow lead in solders for professional, high reliability applications for which viable lead-free alternatives have not been identified. This category is informally referred to RoHS-5.
In brief, other items outside the scope of the RoHS Directive include:
- specialized military systems
- avionics systems
- equipment for national security
- equipment built for own use (hobbyist)
- spares for products placed onto the market before July 1st, 2006
- equipment for capacity expansion or upgrades on product placed onto the market before July 1st, 2006
You can use the 'decision trees' listed below to help review your products - the bottom line is that you must decide whether your product falls within these Directives.
You may wish to seek independent legal advice to support your decision.
What are the Products that are Outside the RoHS and WEEE Directives?
If you decide that your product falls outside of these Directives, it is recommended that you record your decision within your internal product documentation. This may be used to demonstrate due diligence in the event that someone questions the product status. If the product is exempt or falls outside the Directive, there is no legal requirement to mark or make a statement on your published documentation or packaging.
What is required for Products under the WEEE Directive?
The implementation by most European Member States is largely focused on house-hold/consumer WEEE. The essential requirement for business-to-business (B2B) WEEE is as follows:
- Publish your take-back policy
- For product placed on the market before August 13th, 2005 and, if your customer is essentially making a like-for-like purchase (to replace previously supplied product), then you are responsible for the cost of disposal
- If your customer is not replacing the product, the customer is responsible for the cost of disposal
- For product placed on the market after August 13, 2005, you are always responsible for the cost of disposal unless you agree otherwise in your contract with your customer.
- You must register as a producer with an authorized regulator in each Member State. Alternatively, you can register with a number of agency schemes who will deal with this on your behalf. Generally, the registration must be carried out by the producer or producers' representative in each Member State, however, the interpretation of the Directive differs across the EU, so check with your local regulator.
- In most Member States you will also need to mark your product with the symbol (shown here) and indicate when the product was placed onto the market. You should consult with the local regulator for each Member State.
A summary of the implementation status for each member state is provided in the latest Perchards report. (1.3MB .pdf)
What is required for Products under the RoHS Directive?
If you decide the RoHS Directive covers your product and you can demonstrate that you comply, you will need to make a self-declaration (similar to the self-declaration statements made for the European EMC Directive). To support your self-declaration you will need to maintain a technical construction file (TCF) which records your decision and includes all the supporting information such as material declaration forms for each component and sub-assembly used within your product. Remember, for a complex system or instrument to be RoHS compliant, every single solder joint on every circuit board and cable assembly MUST be compliant with the limits defined by the Directive. For marketing purposes, many countries use a variety of symbols to indicate 'lead-free' manufacturing; however, there is no legal requirement to mark the product to indicate compliance with the RoHS Directive.
How are RoHS and WEEE Monitored within the European Union?
The WEEE Directive is monitored formally via the assigned authorities in each Member State. The Directive defines certain recycling and re-use targets, therefore each producer must be registered (separately in each Member State) and report the amount of EEE placed onto the market in each Member State. The producer must also report how much EEE is collected and recycled. The authority will monitor whether you are achieving your targets. In some Member States, the registration, target setting and monitoring are carried out by different organizations. For the RoHS Directive, there is no formal monitoring process or prescribed method for demonstrating compliance and no specific 'marking' required for a RoHS compliant product. If the RoHS Directive covers your product, you must make a self-declaration. Non-compliance can only be highlighted by a third party complaint, by an enforcement authority making a test purchase or by requesting non-existing support documentation. The Enforcement Authority is unlikely to be the Customs & Excise for each Member State (the UK has appointed the National Weights and Measures Laboratory for this role), so a Customs officer does not decide whether a product is compliant or not.
RoHS Product Marking
RoHS-compliant integrated-circuit products can be easily identified by looking for the 'G' postfix. As an example, the RoHS-compliant PD64012 chip will be marked as 'PD64012G,' as can be seen in the picture below.
In Addition, the JEDEC standard marking (sample below) will be clearly marked on every package of RoHS- Complaint products sent to customers.
- One-handed operation of controls and keys
- Twisting, pinching, grasping require less than 5 pounds pressure
- Controls and keys visually and tactilely discernible, including locking status
- Industry standard ports and connectors