Adam wrote in, asking: Does RoHS ever apply to hand tools (non-powered hand tools)?
Hmm… that’s a tough one. RoHS refers to the Restriction of Hazardous Substance Directive that was adapted by the European Union in 2003 and updated recently. More specifically, RoHS refers to Restriction of Hazardous Substances in Electrical and Electronic Equipment.
The electrical and electronic equipment (EEE) part typically refers to solder, which would have to be lead-free to be RoHS-compliant, and other components which previously contained lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE).
In Case You’re Interested: Images from my Research on Lead-Free Solders
Oh, and before you jump to conclusions, the image above has nothing to do with this discussion, aside from how we’re talking about hand tools. That’s Dewalt’s new screwdriver handle – see our Dewalt 2015 mechanics and hand tool preview to learn more.
The aim of the RoHS directive is to reduce the use of hazardous substances in certain products, to contribute to the protection of human health and the environmentally sound recovery and disposal of waste EEE.
It is my understanding that, unless an applicable product is specially exempt in some way, it cannot be imported into or sold in the European Union unless it’s RoHS-compliant.
But this question is entirely out of my familiarity, so let’s take a look at the relevant document.
Looking over the latest version of the directive, and the European Commission website, it seems clear to me that RoHS strictly applies to electrical and electronic equipment. There doesn’t seem to be any reference at all to other types of products.
I did find it interesting that the scope of the directive does not apply to large-scale stationary industrial tools, which are specifically defined in the RoHS document. But again, they’re talking about electronic equipment.
In the listing of categories of EEE covered by the RoHS directive, tools are explicitly mentioned under electrical and electronic tools. There’s also a catch-all “other EEE not covered by any of the categories above” category, but electrical and electronic tools are mentioned, it should be safe to assume that hand tools don’t fall into the catch-all category.
Long story short, I do NOT believe that RoHS applies to non-powered, or non-electrical, hand tools.
I wanted to be sure, so I looked at some hand tool products page, and could not find RoHS compliance information – for most.
I know that some brass hammer heads contain some lead. A RoHS frequently asked questions page by the Copper Development Association Inc. (PDF) mentions some important information about copper and brass alloys that contain lead, but I could not find anything specific about brass hammers in particular. That Copper Development Association page also specifically mentions electrical and electronic equipment.
Then there was Mouser, a huge electronic component supplier, that has details about RoHS compliance regarding what look to be Wera screwdrivers that are distributed by “Phoenix Contact”(link). And there is also information about RoHS compliance “by exemption” for a Wera screwdriver set (link), as it is not technically possible to remove the hazardous substance and maintain the properties of the material.
I’m not sure why those Wera and Wiha screwdrivers were analyzed for their RoHS compliance. They’re manual hand tools, not electrical or electronic equipment. Given what I learned during my recent research efforts, I am still of the belief that the RoHS directive does NOT apply to hand tools. I haven’t a clue as to why Mouser has compliance and compliance exemption info for the two aforementioned examples, rather than a simple N/A (not applicable) mention.
If RoHS compliance is vital to your business, don’t take my word for – do your due diligence and look into the matter with an expert or authority.
For those of you more familiar with RoHS regulations than I am, would your answer differ from mine?