| To analyse every homogeneous material in all but the simplest electrical products is impractical, prohibitively expensive and generally not necessary. ERA use a simple risk-based strategy to assess products, sub-assemblies, components, and materials that can be carried out at minimum cost.
The RoHS Directive 2002/95/EC and similar legislation developing worldwide restricts the use of six materials (lead, mercury, cadmium and hexavalent chromium, and the flame retardants PBDE and PBB) in many products. Based on foundational work carried out by ERA for the UK’s Department of Trade and Industry, the European Commission, and Enforcement Authorities, EU Member States now accept that self declaration by producers backed by market surveillance is the appropriate approach to compliance. Every producer is required to carry out all reasonable steps to ensure that its products comply. This should be based on documentation but some analysis is often required.
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ERA regularly carries out RoHS analysis for clients and frequently finds that components that their suppliers had claimed to comply in fact contained restricted substances. Therefore the risk of non-compliance is very high if no analysis is carried out. |
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UK case law on restricted substances (not RoHS) indicates that some analysis is expected where there is a risk of non-compliance. |
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The RoHS enforcement authorities will expect producers to assess supplier material declarations and not to accept these at face value. |
Approaches to compliance are explained in ERA’s RoHS guide with less comprehensive information from NWML.
1, 2, 3 - a flexible & structured approach to RoHS compliance testing
The authorities will expect producers to demonstrate compliance by compilation of a technical file based on assessed materials declarations from suppliers backed up by selective chemical analysis. ERA can guide you through this selection process to minimise the cost and maximise the effectiveness of RoHS compliance testing using a 3-stage approach.
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Stage 1 – initial assessment
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Assess declarations if available and determine if these can be trusted |
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Determine where there is a risk of non-compliance |
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A critical inspection of the product to assess where restricted substances are most likely to occur. The possibility that exemptions exist for certain uses of restricted substances is considered. The presence of hidden phases within components is also considered at this stage. |
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Decide which materials in which components should be analysed. |
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| Output from Stage 1: |
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a review of data provided |
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a review of the product versus compliance requirements |
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identification of components/parts which constitute a significant risk of containing a restricted substance based on the above and ERA’s wide knowledge. |
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Stage 2 – component and material screening
Data from Stage 1 is reviewed with the client to agree which components or materials should be submitted for screening analysis. ED-XRF, or SEM examination with EDX (or WDX) microanalysis is normally preferred for screening as these will detect Pb, Cd, Hg, Cr and Br. If Cr is detected, it may be necessary to carry out further analysis for hexavalent chromium. If Br is detected in plastics, further analysis will be needed to identify the flame retardant if an assurance that it is not PBB or PBDE cannot be obtained from the supplier.
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Screening analysis is designed to be used to pick up on cases where non compliant materials such as conventional tin/lead lead solder are being used; it is not designed for critical measurements close to the RoHS limits, nor can it distinguish restricted and exempt substances and so, where results are inconclusive, further work will be needed as described in stage 3.
| Output from Stage 2: |
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screening test results on the high/medium risk components selected for analysis |
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recommendations concerning which components should be submitted to more detailed analysis. |
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Stage 3 - specific quantitative analysis
The data from Stage 2 is reviewed with the client who chooses, with advice from ERA, which components to analyse in greater detail. In many cases, screening will be sufficient to show that no restricted substances are present. However, if the presence of restricted substances is indicated additional fully quantitative analysis may be required to verify the concentration level. Appropriate techniques (e.g. ICP, GC-MS) are chosen depending on the element, the sample matrix and size. |
| Output from Stage 3: |
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a description of the methodology used in the assessment |
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results of the Stage 1 review and conclusions |
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results of the Stage 2 screening and conclusions |
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results of the Stage 3 detailed analysis and conclusions regarding product RoHS compliance |
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recommendations for further actions where appropriate. |
Costs
For simple materials a firm quote can be provided. For complex samples, only the initial assessment step would normally be quoted as all other costs will be contingent on this and on subsequent steps. After an initial assessment a limit of liability to cover all subsequent work can be arranged.
All work can be carried out on an individual or call off contract basis or through our subscriber scheme, AccessERA.
ERA’s credentials
ERA’s reliability and failure analysis group (RFA) assisted the UK Department of Trade and Industry (now BERR) and the European Commission develop a practicable approach to demonstrating RoHS compliance. Much of this flowed through to the UK RoHS guidance and the informal RoHS enforcement guidance on which ERA advised. ERA has in depth and hands-on expertise in chemical analytical techniques which was deployed in this work and is also used routinely as part of our analytical forensic services - for example scanning electron microscopy with energy and wavelength dispersive x-ray analysis. ERA is also involved in development of standards under the IEC.
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Environmental Compliance 
