30JEITA-電部第271号
March 27, 2019
Subcommittee on Electronic Components Environment
ESG Committee of Electronic Components Board
Japan Electronics and Information Technology Industries Association (JEITA)

Guideline on the Calculation of the Concentration of RoHS Restricted Substances not being
Part of the originally designed and manufactured Article
Legal Notice and Disclaimer
This document aims to assist users in complying with their obligations under the EU RoHS Directive.
However, users are reminded that the text of the EU RoHS Directive is the only authentic legal reference and that the information inthis document does not constitute legal advice.
Usage of the information remains under the sole responsibility of the user.
The Electronic Components Board of JEITA (Japan Electronics and Information Technology Industries Association) does not accept
any liability with regard to the use that may be made of the information contained in this document.

As of 3/27/2019, the following 10 substances are designated as restricted substances in the EU RoHS Directive(2011/65/EU).
LeadMercury
Cadmium
Hexavalent chromium
Polybrominated biphenyls (PBB)
Polybrominated diphenyl ethers (PBDE)
Bis (2-ethylhexyl) phthalate (DEHP)
Butyl benzyl phthalate (BBP)
Dibutyl phthalate (DBP)
Diisobutyl phthalate (DIBP)
This guideline describes the calculation of the concentration of restricted substances in homogeneous material insituations where these substances were not part of the originally designed and manufactured article, but became
present in the product later from external sources by adhesion, diffusion or similar processes, e.g. from packing
material, storage atmosphere, adjacent components, etc.
1. Need of Criteria for the Calculation of Concentration of RoHS Restricted Substances
The RoHS Directive establishes the duty to ascertain that according with Article 4.1, EEE (electrical andelectronic equipment) placed on the market does not contain the restricted substances listed in Annex II above themaximum allowable concentrations.
The Electronic Component Industry agrees and cooperates with the goal of the RoHS Directive “to contribute to
the protection of human health and the environmentally sound recovery and disposal of waste electrical andelectronic equipment (EEE)”.
However, in case when restricted substances are present after undergoing a process where they become adhered toor diffuse into the equipment from the external sources, it is important to specify the homogeneous material thatbecomes basis for calculation of the concentration.
For such cases, it is necessary to stipulate judgment criteria.
2. Basis for the Calculation of the Concentration of RoHS Restricted Substances not being Part of theoriginally designed and manufactured Article
The scope required for the prevention of restricted substances inclusion, pursuant to Article 4.1 of the RoHS
Directive is established as “EEE placed on the market”; here EEE (electrical and electronic equipment) is definedin Article 3 (1) of the RoHS Directive as “‘EEE’ means equipment which is dependent on electric currents orelectromagnetic fields in order to work properly and equipment for the generation, transfer and measurement ofsuch currents and fields and designed for use with a voltage rating not exceeding 1 000 volts for alternating current
and 1 500 volts for direct current”.

It follows from this that homogeneous materials designed for use as a part of electrical and electronic equipment
and their components should also be used as the basis for the calculation of concentration of restricted substances,
not designed for use, but present in electrical and electronic equipment or their components.
3. Method for Calculation of the Concentration of RoHS Restricted Substances that Become Adhered to or
Diffuse into Electrical and Electronic Equipment and their Components
The Electronic Component Industry recommends that for cases when restricted substances become adhered to or
diffuse into electrical and electronic equipment and their components after its manufacturing, the mass of thehomogeneous material that was originally designed for use as part of such equipment or their components, and towhich the substances become adhered to or diffuse into, shall be used as basis (denominator) for the calculation of
the concentration of the restricted substances.
That is, in the article shown in the schematic diagram below, homogeneous materials [A], [B] and [C] designed
for use as a part of electrical and electronic equipment or its components is used as the basis of calculation of theconcentration of the restricted substances. Therefore, we should calculate the concentration of restricted substancesin homogeneous material [C], including the restricted substance "x" that is not designed for use, but present byadhesion to or diffusion into the article.

Fig. RoHS Restricted Substance "x" that becomes adhered to or diffuses into the articles
This calculation method is in accordance with:IEC 63000:2016, Technical documentation for the assessment of electrical and electronic products with respect
to the restriction of hazardous substances(This document is based on European harmonized Standard EN 50581:2012)
IEC 62321 (all parts), Determination of certain substances in electrotechnical products
IEC 62474:2018, Material declaration for products of and for the electrotechnical industry