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.
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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.
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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?
Eric V.
RoHS deals strictly with electronic and electrical devices. The only reason you might be concerned for a hand tool is if you are working on such devices and worry about contamination. The original concern was for electronic/electrical devices that were ending up in landfills. Lead-free is fine for consumer devices, but most high-end high-reliability devices are still exempt. Aerospace hates lead-free and bans it outright in many applications. It was a fine idea that was taken too far too soon before they realized the difficulties that can occur. Any higher quality rebuildable or repairable device should be exempt.
Phil
RoHS would only apply to tools with a major soldered electronic assembly, such as the speed control in a cordless drill, or battery charger. Hazardous substances such as lead in brass are mostly covered by the California Proposition 65 initiative, with wording about an item containing a hazardous substance known to cause reproductive harm, and since most widely distributed items are likely to find their way to CA, manufacturers go ahead and and affix warning tags or other text on products or packaging on everything that might contain hazardous substances, usually lead. Lead is likely to be found in most common brass items mostly because the raw materials for making brass or other alloys often contain recycled metals. The brass terminals on an extension cord will almost always prompt a warning label, a lot of brass plumbing fittings will have these, even some fixtures used for drinking/potable water. Lead has been used in small quantities in some plastics to change its properties, which is why you’ll sometimes still find some all-plastic items with a Prop 65 tag. These tags seem nearly ubiquitous.
fred
I try to look at Prop 65 tags and “take them with a grain of salt” so to speak. I recently bought some solid brass switch and outlet plates that came with the warning – and kind of scratched my head to figure out how much of a lead exposure hazard they could possibly be.
Tool aficionados will see also Prop 65 warnings on some tools that contain brass or bronze components. As an example,if you look at the Lie Nielsen web site and search on Proposition 65 here’s what you get:
https://www.lie-nielsen.com/search?q=proposition+65
David Stoker
What is involved to get a product posted on you Toolguyd site?
Timing?
Costs?
Please have someone reply to my email.
Stuart
As I mentioned to you 3 months ago, “I need more information and imagery, and a test sample if you’re interested in a review.”
To be frank, all that’s needed to get a product discussed on ToolGuyd is interest (readers’ or my own), information, and usually at least 1 publishable image.
Respectfully, you emailed in with the vaguest description of a tool that I have ever seen, and a phone number for me to call you at. After that, when you asked about advertising, you provided me with a 1-sentence description of the tool, but that’s nowhere near enough to base a post around. I even looked at the website your email address is based on, but could not find any tool-related product there.
I can’t tell you what you need to provide, but I can tell you that the information you provided thus far is not enough.
If this is a product you intend to sell, I will also need a price and purchasing information.
Mike
I believe that brass can contain up to 4% lead and still be rohs compliant .
360 brass, which is probably the most widely machined brass, contains only 2 or 3 % lead. So the hammer is likely still compliant even if hand tools are not exempt.
The lead is added to the brass to make the machining process easier.
Bob
Are there any guidelines regarding hand tools used in the assembly and service of electronic equipment and the potential for contamination of the product from the tools?
Kevin
Looks like the link for “latest version of the directive” is messed up. It should probably be: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0065
Stuart
Thank you very much, I have fixed the link!
Tony Stanley
Came across this looking for references on hand tools supplied with EEE. We are finding DEHP in handles (RoHS3 recently restricted).
But just to correct on some above assumptions, ROHS2 applies to any electrical product, not one with major functions. This is a change from RoHS1 to RoHS2 eg a speaking teddy bear didn’t have to comply before, now it does. Its also nothing to do specifically with soldering, it applies to all homogeneous materials, electrical and non-electrical used in any product with that uses electricity. There are some exemptioned uses, such as Pb in copper alloy, and some industry sectors that have later compliance dates. I also think it applies to functional accessories.