UL Certification and the RoHS directive

When the industry was preparing for the July 2006 implementation of this wide-reaching environmental directive, UL understood the need for its constituents and customers to manage any impacts on existing certifications in a predictable, efficient, and cost-effective manner. This guide was created for that purpose.

Information that UL had gathered regarding the impact on electronic products of RoHS material compliance-based changes suggested that there would be very limited impact relevant to end product safety compliance.  There might have, however, been some limited impact on product reliability.

Therefore, unless field evidence indicates the need to do otherwise, for the industries comprising ITE (UL/IEC 60950), consumer electronics (UL/IEC 60065), medical devices (UL/IEC 60601), and laboratory equipment (UL/IEC 61010), UL has adopted the following practice:

• UL does not need to be notified for changes in status for any components or materials that are not identified by UL in the certification file as Safety Critical Components (SCCs), i.e., components and materials described in the UL Follow-up Service (FUS) Procedure. For some product types, SCCs are limited to components or materials that relate to risk of injury or fire. In other product types, SCCs also include components or materials that impact essential equipment performance.
• UL assumes SCCs whose material (or subassembly material) composition has changed substantially to attain RoHS-compliant status will bear a distinct part number from the previous (nonRoHS-compliant) version. This assumption is based on electronic Industry initiatives to identify RoHS-compliant parts.
• SCCs that carry UL Listing or UL Recognized Component status before and after any RoHS-related material change, and that do not incur any change in published ratings (form, fit and function) or conditions of use, shall be presumed to have no impact on the compliance of the overall end product. However, the UL certification (FUS) document will need to be amended to reflect any new part numbers.

For SCCs that are UL Recognized Components but incur a change in any rating or condition of use or have altered performance characteristics that could impact the compliance of the overall end product, an assessment of the impact of the material change will be needed. The scope of the investigation will need to be determined on an individual basis.