RoHS & Reach Compliance
Twin Cities MN Contract Manufacturing Company | RoHS Compliance

Understanding RoHS

RoHS stands for Restriction of Hazardous Substances. It is an ‘EU legislation restricting the use of hazardous substances in EEE and promoting the collection and recycling of such equipment.’ The directive, which is in force since 2003, also supports effective recovery, reuse, and recycling of products. The energy-consuming products are regulated to control the level of hazardous substances they contain: Twin Cities MN Contract Manufacturing Company

Substances RestrictedControl Levels
Lead (PB)<1000 ppm
Mercury (Hg)<100 ppm
Cadmium (Cd)
<100 ppm
Haxavalent Chromium (Cr6+)<1000 ppm
Polybrominated Diphenyl Ethers (PBDE)<1000 ppm
Polybrominated Biphenyls (PBB)<1000 ppm
Bis(2-Ethylhexyl) Phthalate (DEHP)<1000 ppm
Benzyl Butyl Phthalate (BBP)<1000 ppm
Dibutyl Phthalate (DBP)<1000 ppm
Diisobutyl Phthalate (DIBP)<1000 ppm

The first six applied to the original RoHS while the last four were added under RoHS 3.

Concerned Equipment

  • Large household appliances (LHA)
  • Small household appliances (SHA)
  • IT and telecommunications equipment
  • Consumer equipment
  • Lighting equipment
  • Electrical and electronic tools
  • Toys, leisure, and sports equipment
  • Medical devices
  • Monitoring and control instruments 

Products that are deemed specifically out of the scope of the RoHS directive are:

  • Products for military use or designed to be sent into space
  • Products designed to be sent into space
  • Equipment specifically designed and is to be installed as part of another type of equipment 
  • Large-scale industrial tools and fixed installations
  • Large-scale stationary industrial tools
  • Means of transport (apart from certain two-wheeled electric vehicles)
  • Non-road mobile machinery for professional use
  • Products for research and development available on a business-to-business basis
  • Active implantable medical devices

RoHS Compliance:

To comply with RoHS, all products you place on the UK market must:

  • Have a current declaration of the technical file
  • Have a declaration of conformity
  • Be marked relevantly
  • Display the CE label

Use the following checklist to determine if your products are RoHS compliant:

  • Do my components and subassemblies of EEE contain less than the maximum prescribed levels of lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (CrVI), polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four different phthalates (DEHP, BBP, BBP, DIBP)? 
  • Do I evaluate and self-certify my production controls with reference to the measures detailed in the regulations?
  • Do my products have a Declaration of conformity supported by a technical file that shows compliance?
  • Are the Declaration of conformity readily available to be provided to the Office for Product Safety and Standards (Safety & Standards) if asked for?
  • Am I aware that the Declaration of conformity and technical file must be retained for 10 years after the EEE is first placed on the UK market?
  • Do my individual products have a type, batch or serial number showing the manufacturer’s name, address and registered trade name or mark?
  • Do my products display the CE label?
  • If I am an importer placing EEE on the UK market under my name or trademark, does the product comply with all the obligations on the manufacturers?
  • If I am a distributor, does the EEE I distribute marked appropriately and display the CE label?
  • If I am a distributor who modifies the product before distribution, does it comply with all the obligations on manufacturers?

Understanding REACH

REACH stands for: Twin Cities MN Contract Manufacturing Company

Registration:

Chemical producers are required to register safety data for all chemicals produced.

Evaluation:

Experts from member states and the European Agency evaluate safety data for higher volume chemicals and other chemicals of concern.

Authorization:

Chemicals that are “substances of very high concern” (SVHC) are to be phased out and replaced with safer alternative chemicals.

Restriction:

Chemicals may be completely banned, or some uses of the chemicals can be restricted.

Background of REACH

In June 2007, the European Union Regulation (EC) 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) was first released. The regulation came into force on 1st June 2007 and established European Chemical Agency (ECHA) which manages the Technical & Scientific aspects of REACH. This Regulation establishes specific duties and obligations for companies in the European Union (EU) that manufacture or import substances on their own, in preparations, or in articles.

Consideration of REACH

REACH adopted to addresses the production and use of chemical substances and their potential impacts on both Human Health and the Environment and to improve the same from the risks that can be posed by chemicals. REACH also promotes alternative methods for the assessment of hazardous substances in order to reduce the number of tests on animals.

Amendment

Commission Regulation (EU) 2015/830 dated 28 May 2015 amending Regulation (EC) 1907/2006 of the European Parliament and of the Council on REACH and released a list of Substances of Very High Concern (SVHC), 181 substances as per latest SVHC Candidate list, updated on 16 Jan 2018. REACH SVHC list is not a static list and it is updated once in six months, ECHA now added 4 new substances in the list of candidates to the previous list (published on 15 Jan 2019). Thus, the current list now contains 201 substances as on 16 July 2019.

GVP RoHS and REACH Declaration

Golden Valley Products complies with the European Commission’s RoHS 3 (2015/863/EU and 2011/65/EU) Restriction of Hazardous Substances in Electrical and Electronic Equipment.

With respects to RoHS, according to our raw material suppliers, the products we use to produce your parts are neither manufactured with nor contain Cadmium (Cd), Lead (Pb), Mercury (Hg), Hexavalent chromium (Cr6+), Polybrominated biphenyls (PBB), Polybrominated diphenylethers (PBDE), Bis(2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutylphthalate (DBP), or Diisobutyl phthalate (DIBP), above the directive thresholds.

As defined as a “downstream user” per REACH, Golden Valley Products is not required to provide chemical safety reports since our use of our vendors’ products is within the conditions described in an exposure scenario included in the Safety Data Sheets.  At this time, our vendors have stated that the listed products are classified as “articles” where no substance is intended for release from the product and our suppliers indicate the products are not produced with the intentional use of any of the [REACH] 201 SVHC’S ingredients above the maximum allowable amount of 0.1 percent by weight.

Please Contact Us to request a specific certificate of declaration for any of the parts that we manufacture for you and we would be happy to supply one.