RoHS Compliance and the DPP

RoHS has been in force long enough that most electronics manufacturers consider it settled. The passport unsettles it, not by changing what is restricted, but by changing what has to be recorded about it.

What is restricted, and at what level

Directive 2011/65/EU restricts ten substances. Four are heavy metals and six are phthalates or brominated flame retardants, added by later amendment.

The critical phrase is homogeneous material. A limit is not applied to a product, or to a component, but to every material that cannot be mechanically separated into different materials.

Why the technical file is not enough

A RoHS technical file demonstrates conformity. It typically contains supplier declarations, some analytical testing on higher-risk parts, and a conclusion that the product complies.

That conclusion is exactly what a passport attribute cannot use. An attribute asking which restricted substances are present, at what concentration, in which component, needs the underlying numbers. A file recording that every homogeneous material sits within its limit has discarded them.

The data usually exists somewhere — in supplier full material declarations, in test reports, in an IPC-1752A exchange — but it exists as documents rather than as structured values attached to a part number.

Exemptions expire

RoHS permits exemptions for applications where substitution is not technically or scientifically practicable. Lead in certain solders, in specific glass and ceramic applications, and in some high-temperature contexts are long-standing examples.

Every exemption has an expiry date and a renewal process. A product relying on one has a compliance position with a known end date, and renewal is neither automatic nor guaranteed.

• Record which exemption a product relies on, by its entry number, not merely that one applies.
• Track the expiry date against the product, because it determines a redesign deadline.
• Watch renewal consultations, since evidence submitted by industry is what decides them.
• Plan substitution ahead of expiry, because qualification of an alternative material takes longer than the notice period.

The passport makes this considerably easier to manage, because an exemption recorded as a structured attribute against a product can be queried across a portfolio. An exemption recorded in a PDF cannot.

RoHS, REACH and the passport ask different questions

Three regimes touch the same materials and it is worth being precise about how they differ, because teams frequently assume one satisfies another.

RoHS asks a yes-or-no question about ten named substances. SCIP asks a locational question about a much longer and growing list. The passport established by Regulation (EU) 2024/1781 will ask for both kinds of answer, which is why neither existing dataset transfers cleanly into it.

Waar te beginnen

The realistic first move is to change what suppliers return rather than to attempt to reconstruct history.

Specify full material declarations in a structured format for new parts, so that the data arrives as values rather than as a statement of compliance. Then backfill selectively, prioritising the parts most likely to carry a restricted substance and the products with the longest remaining market life.

Attempting to backfill an entire bill of materials to homogeneous material level before starting is how these programmes stall. The parts that matter are a small fraction of the total, and they are identifiable in advance.

Prioritise on two axes. The first is substance likelihood: solders, platings, cable insulation, flexible plastics and anything with a flame retardant carry most of the risk, while a bare aluminium housing carries almost none.

The second is commercial exposure. A product entering its final production year does not justify the same data investment as a platform expected to remain on sale into the next decade, even though both carry identical obligations while they are being placed on the market.