It is more important than ever to ensure sustainability in electronics! Under India’s E-Waste Management Rules, 2022, the revised RoHS (Reduction of Hazardous Substances) guidelines impose strict requirements on makers and manufacturers.

Restricted Hazardous Substances:

Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium (Cr6+), PBBs & PBDEs must not exceed specified limits.

RoHS Applicability:

• Products classified under ITEW 1-16 and CEEW 1-5 are exempt from RoHS compliance only if they were sold before May 1, 2014. This exemption applies only when compliant parts were not available at the time of sale.

• Starting  April 1, 2025, all products classified under the 85 new Electrical and Electronic Equipment (EEE) categories must meet RoHS compliance requirements, ensuring they do not contain restricted hazardous substances.

• Starting April 1, 2028, spares and components of the 85 new Electrical and Electronic Equipment (EEE) categories must comply with RoHS regulations. However, compliance is required only if compliant parts are available at that time.

• Medical, laboratory, and monitoring equipment are exempt from RoHS compliance because they are used in specialized applications where material restrictions could impact functionality, safety, or performance.

• Defense and strategic equipment are fully excluded from RoHS restrictions because they are critical for national security and military operations, where material restrictions could compromise performance, reliability, or safety.

Producers’ Key Responsibilities:

1. Disclose hazardous substances in product manuals.

• Producers must list any hazardous substances present in their products within the product manuals, ensuring transparency and helping consumers and regulators make informed decisions about safety and compliance.

2. Ensure all imported and sold EEE products comply with RoHS regulations.

• Producers must verify that all imported and sold Electrical and Electronic Equipment (EEE) meet RoHS standards, ensuring they do not contain restricted hazardous substances beyond permissible limits.

3. Cover the costs of random regulatory inspections conducted by CPCB.

• Producers are responsible for paying the costs of random regulatory inspections carried out by the Central Pollution Control Board (CPCB) to verify compliance with RoHS regulations.

4. Recall any non-compliant EEE products from the market.

• Producers must remove and recall any EEE products that fail to meet RoHS compliance from the market to prevent the sale and use of non-compliant items.

Regulatory Oversight & Testing:

1. CPCB will carry out random inspections to ensure compliance.

• The Central Pollution Control Board (CPCB) will conduct random inspections of Electrical and Electronic Equipment (EEE) to verify RoHS compliance. 

• These checks ensure that products do not contain restricted hazardous substances beyond permissible limits and that manufacturers adhere to regulations.

2. Non-compliant products must be withdrawn, and corrective actions must be taken.

• If a product is found non-compliant with RoHS regulations, it must be removed from the market to prevent further sales. 

• Additionally, manufacturers are required to take corrective actions, such as modifying the product design, replacing restricted substances, or improving compliance processes, to meet RoHS standards.

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