RoHS Recast – New standards in progress

The new RoHS directive 2011/65 requires the CE mark and the EU declaration of conformity as a proof of compliance with the legislation. In order to being able to issue those evidences, a technical documentation (according to the EU decision 768/2008) is required. As the new RoHS is based on a presumption of conformity if a device carries the CE mark, harmonized standards are absolutely essential for industry but don’t exist yet. Therefore, the European Commission has recently mandated the three most important European committees and institutes CEN, CENELEC and ETSI to develop new standards for RoHS compliance. Those standards should enable manufactures of electrical and electronic equipment (EEE) to proof compliance with the substance restrictions and limitations in homogeneous material via e.g. testing results, material declaration or contractual agreements between manufacturers and suppliers. The standards should be convertible for all sizes of enterprises e.g. small and medium sized enterprises (SME). The process of creating and issuing the new standards will take approximately one year. A publication of the new standards is therefore expected not before end of September 2012. This may result in shortage of time for manufactures, as the implementation into national legislation has to be realized until January 2, 2013 and will be legally valid then. Although having no harmonized standards yet, manufacturers of EEE should start working on their technical documentation now. If, at the beginning of 2013, the required documentation for CE marking cannot be provided, the devices won’t be allowed to be put on the European market.