NELMA is often asked about the implications of a packaging requirement known as “RoHS” versus the IPPC ISPM 15 Standard. As many exporters are aware, RoHS compliance is being requested by overseas customers, both in Europe and now China.

 

RoHS is an export manufacturing directive that began in Europe and stands for "the restriction of the use of certain hazardous substances in electrical and electronic equipment".  This Directive bans the placing on the EU market of new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants.

 

While it was adopted in February 2003 by the European Union, the RoHS directive took effect on July 1, 2006. It is not considered a law, but a directive.   However, each EU member state will adopt its own enforcement and implementation policies using the directive as a guide, with their own set of variations. Effective March 1, 2007, China adopted a similar version of the directive which became known as “China RoHS”. The confusion quickly begins when requests from a foreign customer for the labeling of the “packaging” becomes a requirement. What is meant by the term “packaging” when it comes to RoHS labeling is typically marks and symbols applied directly to the consumer electronic products being packaged for retail that indicate, for example, “No RoHS substances”, “reusable” or “recyclable”.