RoHS 2 impacts on use of electronics in footwear

The RoHS 2 directive will have a significant impact on the footwear industry.

January 2013 is the date set for the implementation of the RoHS 2 (Restriction of Hazardous Substances) directive into national legislation by all member states of the European Union. RoHS 2 is a European directive 2011/65/EU, which was published in July 2011. It is intended to recast the previous RoHS directive 2002/95/EC.

Under the previous RoHS directive, exemptions were granted for products where the primary function of the product was not dependent on its definition as EEE (Electrical and Electronic Equipment), although suppliers were expecting to be working towards compliance. However, under the recast of the directive, the definition of EEE will include all products which contain batteries. Electronic components will need to comply with the requirements of RoHS 2, whether their primary function is based around the EEE element or not. This will have a significant impact on the footwear industry, as this will now mean that items such as trainers with light-up heels or sports shoes containing step counters will now be covered by the legislation.

Therefore, after 2nd January 2013, all EEE that was within the scope of RoHS 1 is expected to carry the CE mark, which will show that the product is in compliance with the requirements of this directive.

The substances limited by RoHS 2 are as follows:

• Lead (0.1 per cent)
• Mercury (0.1 per cent)
• Cadmium (0.01 per cent)
• Hexavalent chromium (0.1 per cent)
• Polybrominated biphenyls (PBB) (0.1 per cent)
• Polybrominated diphenyl ethers (PBDE) (0.1 per cent)

Products that were outside the scope of RoHS 1, except medical devices, monitoring and control instruments, do not need to comply with the new regulation until 22nd July 2019.

RoHS 2 will have a significant impact on the footwear industry, as this will mean that items such as trainers with light-up heels or sports shoes containing step counters will be covered by the legislation.

Publishing Data

This article was originally published on page 3 of the January 2013 issue of SATRA Bulletin.

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