How Europe and the US Take Different Stances on PCB Material Regulation

May 14, 2020 by Vanessa Samuel

Why is the European Union so much stricter about what goes into a PCB?

The United States and the European Union have always differed when it comes to the regulation of materials and products distributed through their countries.

Regulations for electronic material are no different.

The EU has a couple of standards it follows: the Reduction of Hazardous Substances (RoHS) and Waste from Electrical and Electronic Equipment (WEEE). The U.S. abides by protocols from the National Institute of Standards and Technology (NIST) outlined in a guide to U.S. electrical and electronic equipment compliance requirements.

Let’s examine the key differences in their regulations and how this affects engineers. 


What Counts as Electrical and Electronic Equipment (EEE)?

U.S. companies that sell, manufacture, or distribute electrical and electronic equipment (EEE) to the EU must comply with RoHS and WEEE standards.


Wheely bin sticker

"Wheely bin" sticker that indicates WEEE compliance. Image used courtesy of the European Commission

The U.S. Commercial Service defines EEE as "equipment which is dependent on electric current or electromagnetic fields in order to work properly, and equipment for the generation, transfer and measurement of such currents and fields, and designed for use with a voltage rating not exceeding 1000V for AC and 1500V DC." 

In this sense, RoHS applies to any product that requires an electric spark to begin operating.


The Metals and Phthalates in PCBs

These regulations end up affecting engineers, specifically in the type of materials that go into components and circuit boards.


PCBs include metals and phthalates

PCBs include metals and phthalates—some that are permissible in the U.S., some that aren't in Europe. Image used courtesy of Johannes Plenio

Below is a list of the metals and phthalates used in PCBs. 

  • Lead (Pb) in solder
  • Mercury (Hg) in sensors, switches, and relays
  • Cadmium (Cd) in batteries, chip resistors, semiconductors, and other metals as a source of corrosion resistance
  • Hexavalent chromium (Cr6+) used as corrosion resistance on metals
  • Polybrominated biphenyls (PBB) used as flame retardant and lubricant in transformers, capacitors, and other electronic components
  • Polybrominated diphenyl ether (PBDE) used as a flame retardant
  • Bis(2-ethylhexl) phthalate (DEHP) used in cable and wire insulation
  • Butyl benzyl phthalate (BBP) co-plasticizer in wire and cable and as an additive in flexible adhesives
  • Dibutyl phthalate (DBP) used as a plasticizer in flexible varnishes
  • Diisobutyl phthalate (DIBP) similar to DBP, but not normally used in electronic products


Do U.S. Manufacturers Comply With RoHS?

As outlined in our 2020 starter guide to RoHS, the Reduction of Hazardous Substances was introduced to the EU in 2003 and periodically updates its parameters to combat the proliferation of e-waste.

RoHS makes a 0.1% max concentration (by weight) limit on the following heavy metals except for cadmium, which is .01%:

  • Lead (Pb) 
  • Mercury (Hg) 
  • Cadmium (Cd) (.01%)
  • Hexavalent chromium (Cr6+) 
  • Polybrominated biphenyls (PBB) 
  • Polybrominated diphenyl ether (PBDE)

The U.S. federal government does not have explicit regulations on the heavy metals above. However, they support the voluntary ENERGY STAR Program for EEE products. This is a joint program created by the Environmental Protection Agency (EPA) and the Department of Energy (DOE) that sets energy-efficiency specifications in over 70 product categories, including electronics.

For more stringent guidelines with metals and phthalates in PCBs, one must look to regulations established by state governments. Some states require that electronic materials comply with RoHS; electronics that do not comply are prohibited from being sold in that state. 


Why Europe Is Stricter on Electronic Toxicity

Why does Europe seem so much stricter in electronic material regulations?

The European Commission (EC) abides by the precautionary principle when discussing new laws and policies. The precautionary principle informs environmental policymakers to take precautionary measures if they see any potential for a material to harm a person, animal, or the environment. By answering a series of questions, companies can determine whether or not they need to put the precautionary principle into action. 


Precautionary principle

The European Commission abides by the "precautionary principle" when making decisions in the face of uncertainty. Image used courtesy of the European Commission


The EC looks at toxicity over performance before taking action. U.S. policies differ in that they typically set a high bar for proof of harm before regulatory action is taken. Also, the U.S. government does not strictly enforce the ENERGY STAR Program, which could lead to prioritizing performance over the toxicity of a material.


Toxicity vs. Performance

Restricted materials are distributed throughout PCBs, and the balance of toxicity vs. performance of the materials can seem like a burden to engineers. But by complying with RoHS and other e-material regulations, developers can ensure that their devices can be distributed in both the U.S. and Europe. 

These regulations may also spark further innovation with new materials that are suitable for the environment and deliver high performance, like lead-free solder.


Learn More About E-Waste and E-Material Regulations

E-Waste: The Seedy Underbelly of PCB Disposal

The Ethics of E-Waste: Are Engineers Culpable for the 50 Million Tons of Electronic Waste?

What Does the War Against E-Waste Look Like?

Electronics Recycling: Why Do Some Facilities Reject E-Waste?

What Is RoHS and Why Is It Important?



Have electronic materials regulations ever affected the way you sourced components for a design? Share your experience in the comments below.