UK National Measurement Office - Study Results on EU RoHS Compliance

Studies show that there is still room for improvement for the EU RoHS directive.

UK Study Focuses on RoHS Compliance

The EU RoHS directive has been in place since 2006, however a recent study by the UK National Measurement Office (NMO), the “Higher Priced Toys Purchasing Project,” concluded that 40% of the purchases failed for either EU RoHS and / or the EU Battery Directive requirements.

The NMO identified 5 different toy categories: educational, sports and outdoors, musical, ages under 3 years, and ages over 3 years. Three price categories were identified: £30.00 – £49.99, £45.00 – £59.99 and greater than £60.00. The actual purchase price of the items ranged from a low of £30.00 to a high of £104.90. The risk analysis considered availability on the market and the popularity of retailers. It included brick and mortar retailers as well as internet sales channels to select product manufacturers.  A total of 15 products were purchased in June of 2014 by NMO enforcement personnel and submitted for laboratory analysis.

Failure Rate for RoHS Compliance at 40%

- One educational toy purchased from a retailer for £30.00 failed for RoHS content and RoHS marking.
- One educational toy purchased from a retailer for £99.99 failed for RoHS marking and the Battery Directive.
- One sports and outdoor toy purchased from a retailer for £36.98 failed for RoHS content, RoHS marking and Battery Directive.
- One 0 to 3 year toy purchased from an importer/distributor for £35.00 failed for the Battery Directive.
- One 0 to 3 year toy purchased from an importer/distributor for £59.99 failed for the Battery Directive.
- One 3 + year toy purchased from a £104.90 from a retailer failed for RoHS content and the Battery Directive.
- 3 of the 6 items that failed were “ride on” type toys.
- Testing results:
a. Total Items Tested   15
b. Total Items Passed   9
c. Total Items Failed     6
d. % Items Failed         40
e. Results will be shared with the Administrative Co-Operation Group (ADCO) to assess whether toys are an EU wide concern.

Additional RoHS Testing Recommended

Based upon the limited sample size it is not possible to draw any statistically sound conclusions, but the results indicate that the methods used to risk assess items and sources appear to validate the predicted results:

- 4 of the 5 companies projected to be high risk placed a non-compliant toy on the market
- 1 company from both the medium and low risk categories placed a non-compliant toy on the market

Due to the high number of ‘ride on” type toy failures observed, the NMO is recommending that they focus more intently on this type of toy.

The NMO is recommending that testing continue in 2016/2017 for small and medium sized enterprises including online e-tailers.

Study Conclusion

The sample size does not allow for a statistically valid indication of the targeted market segment but it does continue to re-enforce that the supply chain is still struggling with compliance. The findings demonstrate that suppliers and product manufacturers must continue to exercise “reasonable due diligence” to validate the material composition of their products. The industry has come a long way, but the struggle to achieve and maintain compliance is ongoing.

Reference:

Higher Priced Toys 2014 RoHS Report

About SGS Hazardous Substances Services

SGS supports manufacturers and retailers worldwide with the management of hazardous substances in consumer products. Through global expertise and a network of chemical labs, SGS can help companies ensure products’ compliance with the EU RoHS directive and relevant hazardous substances requirements on any market around the world.

For more information on SGS hazardous substances services, contact an SGS expert.

Contact details:

SGS Consumer Testing Services
Kenneth Stanvick
Technical Manager, Environmental Compliance Management
SGS North America Inc.
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Fairfield, NJ 07004 USA

t: +1 603-305-4103
Email: [email protected]  
Website: http://www.sgs.com/rohs

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