Key takeaways
- RoHS applies to almost all electrical and electronic equipment up to 1,000 V AC or 1,500 V DC, including lamps, lighting chains and battery-powered LED décor.
- Each of the ten substances is limited per homogeneous material, such as a solder joint, cable sheath or paint layer, not per whole product.
- RoHS is part of CE marking: the manufacturer keeps technical documentation, usually to EN IEC 63000:2018, and lists RoHS on the EU Declaration of Conformity.
- Under WEEE the producer is the EU company that places the goods on each national market, usually the importer; it registers with each country's register and finances recycling.
- An inspection checks the bin symbol, CE marking, labels and documents; substance content needs XRF screening and chemical tests in a lab.
Which products are covered
Both Directives use the same definition of electrical and electronic equipment (EEE): equipment that depends on electric currents or electromagnetic fields to work properly, with a voltage rating up to 1,000 V AC or 1,500 V DC. "Depends" means it needs electricity for at least one intended function. Unlike the Low Voltage Directive, there is no lower voltage limit, so a battery-powered LED candle or string light is covered.
| Item | RoHS 2011/65/EU | WEEE 2012/19/EU |
|---|---|---|
| Luminaires (table, floor, wall lamps) | Yes, category 5 lighting equipment | Yes, large or small equipment depending on size (over or under 50 cm) |
| LED lamps and other light sources | Yes | Yes, category 3 lamps; filament bulbs are excluded |
| Lighting chains and battery LED décor | Yes | Yes |
| Cables and spare parts for EEE | Yes | As part of the equipment |
WEEE has applied to all EEE (open scope) since 15 August 2018. Furniture with built-in lights or motors may also be in scope; agree the classification with your buyer.
RoHS: the ten restricted substances
| Substance | Maximum by weight in homogeneous material | Where it can show up in lamps and décor |
|---|---|---|
| Lead (Pb) | 0.1% | Solder, brass parts, PVC stabilisers, glass, paint |
| Mercury (Hg) | 0.1% | Some light sources and switches |
| Cadmium (Cd) | 0.01% | Pigments, plating, PVC |
| Hexavalent chromium (Cr VI) | 0.1% | Chromate passivation on metal parts |
| Polybrominated biphenyls (PBB) | 0.1% | Flame retardants in plastics |
| Polybrominated diphenyl ethers (PBDE) | 0.1% | Flame retardants in plastics |
| DEHP | 0.1% | PVC cords and cable sheaths |
| BBP | 0.1% | Plasticised PVC, adhesives |
| DBP | 0.1% | Plasticised PVC, inks |
| DIBP | 0.1% | Plasticised PVC |
A homogeneous material is one that cannot be separated mechanically, such as a solder joint, a cable insulation layer or a paint coat. Annexes III and IV list time-limited exemptions for specific uses, for example lead in some copper alloys. Check the current exemption list and expiry dates for your product category.
RoHS works through CE marking. The manufacturer uses internal production control (Module A), keeps technical documentation and the Declaration of Conformity for 10 years, and affixes the CE marking. EN IEC 63000:2018, published in the Official Journal by Decision (EU) 2020/659, is the harmonised standard for that technical documentation. The importer checks the CE marking and documents, adds its name and address, and keeps the Declaration for 10 years.
WEEE: producer registration and the bin symbol
WEEE is about end of life. Under Article 3, a producer is a company established in an EU country that sells EEE under its own brand there, resells others' EEE under its own brand, or places EEE from another country on that market on a professional basis. A seller that ships directly to households or users in another EU country, or from outside the EU, is also a producer there.
- Registration. Each producer registers with the national register in every EU country where it places EEE on the market (Article 16). A distance seller not established there registers through an authorised representative appointed by written mandate (Article 17).
- Financing. Producers finance collection, treatment and recycling of waste from their products placed on the market after 13 August 2005, individually or through a collective scheme, and provide a financial guarantee (Article 12).
- Marking. Products carry the crossed-out wheeled bin symbol in Annex IX, printed visibly, legibly and indelibly, preferably to EN 50419 (Article 14(4)). Where size or function makes that impossible, it goes on the packaging, instructions and warranty. A mark must also show that the product was placed on the market after 13 August 2005 (Article 15(2)).
For an Indian exporter selling to an EU importer, the importer is usually the WEEE producer in its own country. Registration and fees are national and differ by country.
What this means for exporters in India
RoHS risk in Indian lamps and electrical décor usually comes from bought-in parts rather than the main body:
- PVC cords and cable. Cheaper PVC can contain DEHP or lead-based stabilisers. Use cord from a supplier that provides RoHS test reports for the exact cable.
- Solder and PCBs. LED drivers and switch boards need lead-free solder unless an exemption applies.
- Brass and plated metal. Brass bodies and fittings from Moradabad can contain lead; the exemption for lead in copper alloys has limits. Chromate passivation can leave hexavalent chromium.
- Paints and pigments. Lead or cadmium in paint on lamp bases and shades.
- Labels and artwork. The bin symbol, CE marking and importer details must be on the product or, if impossible, the packaging, as agreed with the buyer.
Keep a bill of materials per style with each part's supplier and its RoHS test report, and re-test when a supplier changes.
What inspection can check, and what needs a lab
| An inspector at the factory can check | Needs a lab |
|---|---|
| Crossed-out wheeled bin symbol present, legible and durable on product or, where agreed, packaging | XRF screening of each homogeneous material for lead, mercury, cadmium, total chromium and total bromine |
| CE marking, model or batch number, manufacturer and importer details | Chemical tests to confirm hexavalent chromium, PBB and PBDE where XRF finds chromium or bromine |
| Declaration of Conformity lists RoHS; RoHS test reports on file for cords, drivers and metal parts | Phthalate tests (DEHP, BBP, DBP, DIBP), which XRF cannot detect |
| Parts in production match the bill of materials and the tested components |
RoHS test methods are set out in the IEC 62321 series. XRF is a screening tool: a clear XRF result supports compliance for the elements it measures, while an unclear one needs chemical confirmation.
How Clear To Load checks this in India
During a pre-shipment inspection in India, the inspector checks the bin symbol, CE marking and label content against your artwork, compares cords, drivers and metal parts with the tested components, and photographs the documents on file. For RoHS testing, we draw and seal samples for an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination. We have no partner labs and take no lab commissions.
The report arrives within 24 hours of the inspection and ends in Cleared to load, Hold or Not cleared. See also home décor and handicrafts inspection, or book an inspection.
Sources
- Directive 2011/65/EU (RoHS) (EUR-Lex)
- Commission Delegated Directive (EU) 2015/863, four phthalates added to RoHS Annex II (EUR-Lex)
- Commission Implementing Decision (EU) 2020/659, EN IEC 63000:2018 (EUR-Lex)
- Directive 2012/19/EU (WEEE) (EUR-Lex)
- European Commission: Waste from electrical and electronic equipment