Heavy Metal Compliance per RoHS Directive - Case Study


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Compliance with RoHS (or the Restriction of Hazardous Substances Directive) is an important issue in manufacturing today. RoHS has been constantly evolving since its original adoption in the EU as RoHS 2002/95/EC in 2003. Its full name is “Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment.”

As the full name indicates, RoHS applies to finished electrical and electronic equipment. The maximum tolerated concentration of Lead (Pb), Mercury (Hg), Hexavalent chromium (Cr6+), Polybrominated biphenyls (PBB), and Polybrominated diphenyl ether (PBDE) is 0.1% in homogeneous materials and for Cadmium (Cd) is 0.01%. Other regulated materials include:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

These four phthalates were added as part of Directive (EU) 2015/863, published in 2015. The maximum tolerated concentration of each of these is 0.1% and regulation of these additional four substances will be applied in 2019. There are over 80 exemptions, including automobiles and some medical devices. The exemption of these medical devices will expire in 2021.

In addition to the above chemical / elemental restrictions, products regulated by RoHS2 must display the CE mark. In the past, other unofficial marks or logos have been tolerated, but RoHS 2 requires the “CE” mark to indicate RoHS compliance.

A manufacturer of laboratory instruments needed to comply with RoHS regulations. This manufacturer had completed a factory audit and training with a third-party consultant. The audit and training revealed that RoHS testing was still required. Additionally, besides RoHS, REACH and CA Prop 65 compliance was necessary as well because of where the instruments are sold. REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is an EU regulation in effect since 2006 that addresses chemical substances and their impact on health and the environment. California Proposition 65 (also known as the Safe Drinking Water and Toxic Enforcement Act of 1986) requires manufacturers to label products which contain chemicals the State deems as known to cause cancer or birth defects or other reproductive harm.

The chief challenge was screening components quickly, efficiently, and accurately. It needed a robust audit trail and the ability to capture high-resolution sample images to support that audit trail. But most importantly, it needed to increase testing frequency while reducing the potential costs of non-compliance and additional testing.


This manufacturer chose the HD Mobile ® portable handheld XRF analyzer from XOS. The process was simple and quick, with screening measurements taking only 30 seconds. Over 75 components regulated by RoHS were able to be screened in 2-3 hours, by one operator. Use of the HD Mobile analyzer enabled pinpoint accuracy, due to the small spot size of the analyzer. Additionally, the mobile test stand could be used frequently to enable hands-free operation. And high-resolution sample images captured for each measurement by the instrument made a robust audit trail possible. All of these factors eliminated the costs of additional testing and greatly mitigated the risk of non-compliance, offering this manufacturer a high degree of assurance that its products are compliant and its brand is secure.


Using the HD Mobile ® portable handheld XRF analyzer, this manufacturer ensured compliance with confidence. Taking HDXRF technology out of the lab and onto the manufacturing floor, the manufacturer gained the accuracy of HDXRF with the portable convenience and flexibility of a handheld analyzer.

To learn more about why the HD Mobile ® is the ideal solution for RoHS compliance, please visit www.xos.com or contact us at info@xos.com.

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