Regulatory Open Forum

Dear Community,

I am looking at the Directive 2011-65-EU and Annex II maximum concentration values tolerated by weight in homogeneous materials (all are below 0.1 % = 1000ppm).

From the definition: "'homogeneous material' means one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes;" can you advise if there is a case in which the device has two components, each containing say 600 ppm of hexavalent chromium (both below the maximum concentration value by weight), are considered compliant? Or, the two separate parts' concentrations should be added together and counted as the total for comparison to Annex II limits?

Any thoughts/comments are highly appreciate.

Thank you in advance!

Hi Ana

If you added up the weight of the stuff within the parts and then divided by the total weight of the parts, you'd still be below the limit.

But the rule is to treat each part separately. Each one must be below the limit.

If every part, every coating, every adhesive, everything is below the limit for that substance, it's all compliant with the RoHS rule.

Dear Community,

I am looking at the Directive 2011-65-EU and Annex II maximum concentration values tolerated by weight in homogeneous materials (all are below 0.1 % = 1000ppm).

From the definition: "'homogeneous material' means one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes;" can you advise if there is a case in which the device has two components, each containing say 600 ppm of hexavalent chromium (both below the maximum concentration value by weight), are considered compliant? Or, the two separate parts' concentrations should be added together and counted as the total for comparison to Annex II limits?

Any thoughts/comments are highly appreciate.

Thank you in advance!