Response to RoHS2

The RoHS Directive (2002/95/EC) was published in the EU Official Journal as the revised RoHS Directive on July 1, 2011, under 2011/65/EU. 2002/95/EC is known as RoHS1, and 2011/65/EU as RoHS2. RoHS2 was to be transposed into national law by EU countries by January 3, 2013, replacing RoHS1 and is currently in effect.

It's important to understand that RoHS1, the 'old RoHS Directive,' and RoHS2, the current RoHS Directive (2011/65/EU), are not the same. Complying with RoHS1 does not automatically mean compliance with RoHS2. To ensure adherence to the current RoHS Directive, conforming to the newly added regulatory contents is essential. Here's a summary of these changes:

Prohibited substances and maximum premissible concentration

The RoHS Directive identifies substances whose use is restricted, known as prohibited substances. The original RoHS Directive was initially issued as 2002/95/EC; its revision, 2011/65/EU, designated six substances (groups).

However, on June 4, 2015, Regulation (EU) 2015/863 was published in the Official Journal, adding four phthalate substances to the list. With the addition of these four substances, the total number of prohibited substances (groups) has reached ten. Regulation (EU) 2015/863 serves as a replacement for Annex II of 2011/65/EU, and it specifies the ten substances (groups) along with their allowed concentrations (maximum permissible concentrations).

RoHS1 Prohibited Substances

• Lead: 0.1 w% (1,000 ppm)
• Mercury: 0.1 w% (1,000 ppm)
• Hexavalent chromium: 0.1 w% (1,000 ppm)
• PBB (polybromobiphenyl): 0.1 w% (1,000 ppm)
• PBDE (polybromodiphenyl ether): 0.1 w% (1,000 ppm)
• Cadmium: 0.01 w% (100 ppm)

Prohibited Substances Added to RoHS 1 in RoHS 2

    DEHP (di-2-ethylhexyl phthalate): 0.1 w% (1,000 ppm)
    BBP (butyl benzyl phthalate): 0.1 w% (1,000 ppm)
    DBP (di-n-butyl phthalate): 0.1 w% (1,000 ppm)
    DIBP (diisobutyl phthalate): 0.1 wt% (1,000 ppm

Target product (item) · Target category

The outline of the target product is an electrical and electronic device used in a voltage range not exceeding 1,000 V AC and 1,500 V DC (DC) as in RoHS 1, but "Equipment dependent on electromagnetic field, or Equipment for generating, conducting, measuring electromagnetic field "condition is added.

In RoHS 1, the target was ten categories, but RoHS 2 added the eleventh category as "other electrical and electronic equipment." Also, in Categories 8 and 9, which were not covered by RoHS 1, the application start date was determined, and all of the 11 categories specified were covered.

• Large household electrical equipment
• Small household electrical equipment
• Information technology (IT) and telecommunications equipment
• Consumer electronics
• Lighting device
• Electrical and electronic tools (excluding large stationary machine tools)
• Toys, leisure and sporting goods
• Medical equipment
• Monitoring and control equipment
• Vending machine
• Other electrical and electronic equipment not applicable to the above categories

Regulation start time

The time when regulation of 10 substances in total including 4 substances added this time is started is determined by category.

• Categories 1 to 7, 11: July 22, 2019
• Category 8, 9: July 22, 2021

Correspondence of our AC adapter

Our company has been proactively preparing for the end of 2015 and, starting around August 2016, sequentially explaining the RoHS2 Directive in writing to our component suppliers with whom we have transactions and demanding compliance. Since January 1, 2017, we have been purchasing components that comply with RoHS2 (Directive 2015/863EU). Compliance with RoHS2 will also be a condition for adopting new manufacturers.

We revised our "RoHS Product Management Regulations" ISO document and started using it as part of the manufacturer factory audit documentation on December 25, 2015.

Regarding the SGS report, starting on January 1, 2017, we will also manage the four additional substances in the same manner as the six substances under RoHS1, ensuring that all ten substances comply with the RoHS2 Directive.

　Please click here to download the RoHS2 non-use of restricted substances certificate.