RoHS 2 DIRECTIVE 2011/65/EU Supersedes RoHS 1 since Jan. 2, 2013

The RoHS 2 Directive prevents all EEE placed on the European market from containing more than  0.1 % of Pb (Lead), 0.1% of Hg (Mercury), 0.01% of Cd (Cadmium), 0.1% of CrVI (Hexavalent Chromium), 0.1% of PBB (Polybrominated biphenyls) and 0.1 % of PBDE (Polybrominated diphenil ethers).

New EEE categories have been added to RoHS 2 scope (annex IV):

  • Medical  devices
  • Monitoring and control equipment

Compliance of equipment with the RoHS 2 directive is required before the placement of CE mark and must be clearly mentioned in the Declaration of Conformity by the manufacturer of the equipment.

The RoHS 2 requirements apply to equipment/end products that fall within the scope of the directive.Components such as EMI shielding gaskets are not covered by the scope of the directive.  However, for the final product to be compliant, it is obvious that each of its components must ensure that restricted substances are within the admissible concentration values.

Schlegel Electronic Materials, Inc. (SEM) considers the RoHS Directive a very important step for a clear understanding of the environmental impact of substances in equipments during the product life and/or when recycled.  Therefore, and from day 1, all SEM gaskets combinations have been designed and tested so as to guarantee the compliance with the Directive. To ensure consistency of compliance in time, SEM  put in place a special quality procedure  in the production line to ensure that allowable limits are not  reached. Technical reports are available on request as well as Certificate of Conformity being supplied with every order.

Schlegel Electronic Materials, Inc. (SEM) is pro-actively proposing a Halogen Free (IEC61249-2-21)  EMI shielding range of products as we believe that these substances will be considered for inclusion in future RoHS legislation .

Schlegel Electronic Materials, Inc. (SEM) is also in compliance with the 4 new  restricted substances which should be added in annex II of the Directive before 2018   (Flame retardant HBCDD and phthalates DEHP, BBP and DBP).

European Registration, Evaluation and Authorization of Chemicals REACH regulation

After reviewing the obligations and responsibilities that affect business operating in Europe, Schlegel Electronic Materials, Inc. (SEM) has determined that we are suppliers of “Articles” to consumers, and that we bound to comply with the relevant pieces of the legislation based on this determination  (reference:  Annex 1 for definitions and explanations in “Guidance on requirements for substances in articles”).    “An Article means an object which during production is given a special shape, surface or design which determines its function to a greater degree that does its chemical composition”.

As such, our fabric over foam products are not a candidate for the REACH registration and declaration. We do not sell chemicals, including preparations (e.g. adhesives (liquid), solvents, coolant materials, etc).  Our product does not emit gases or vapors.  Thus we are not obligated for the REACH registration and declaration.

However ,SEM keep track on the list of Substances of Very High Concerns (SVHC– Article 59(10) of the REACH Regulation ) to guarantee that none of these substances can be found in our products .The list of banned chemicals being updated on a regular basis ,SEM ‘s reference is made with the latest one available on the website of the European Chemicals Agency (ECHA).

European Directive on Waste Electrical and Electronic Equipment (WEEE)

None of the SEM fabric and foam combinations available since  January 2002  should be removed from the Electrical and Electronic Equipments before recycling  according  to Annex 7 of Directive 2012/19/EU on Waste Electrical and Electronic Equipment entered into force on 13 August 2012 and  effective on 14 February 2014.