Saudi Arabia begins implementation of RoHS for electrical and electronic products

SGS explores what this means for manufacturers and exporters.

On July 9, 2021, the Saudi Standards, Metrology and Quality Organisation (SASO) announced the introduction of the country’s RoHS, bringing it into closer alignment with EU requirements for EEE. This decision follows market surveillance that discovered products containing substances that could present a serious threat to the environment and consumer health.

Scope

Under SASO RoHS, all identified EEE products must undergo assessment by a recognised conformity assessment body (CAB) before being placed onto the market. CABs are responsible for evaluating the type of product and identifying the correct HS code, listed in six product categories for illustrative purposes only. This will determine whether the product is within the scope of RoHS.

Equipment under the scope of RoHS includes:

• Household appliances
• Information and communication technology
• Lighting
• Electrical and electronic tools
• Leisure, recreation and sports equipment
• Monitoring and control devices
• Products exempt from SASO RoHS include:
• Medical devices
• Weapons and military equipment
• Aerospace products
• Large-scale stationary industrial tools
• Large-scale fixed installations

In addition, all spare parts relating to the main EEE products are exempted from RoHS regulation.

Stakeholders should be aware that medical devices and monitoring equipment fall under the scope of the Saudi Food and Drug Authority.

RoHS requirements are added to existing EEE product requirements – for example, GSO Low Voltage regulation, etc. – and do not require separate certification. The CAB will only issue a single certificate and it is their responsibility to ensure all requirements, including RoHS, are incorporated into the product’s technical file.

Chemical requirements

Products within the scope of SASO RoHS must undergo conformity assessment to ensure they do not exceed the following chemical restriction levels:

• Lead (Pb) – 0.1%
• Mercury (Hg) – 0.1%
• Cadmium (Cd) – 0.01%
• Hexavalent chromium (Cr) – 0.1%
• Polybrominated biphenyls (PBBs) – 0.1%
• Polybrominated diphenyl ethers (PBDEs) – 0.1%

Implementation

To ensure a smooth transition to the new regulation, SASO has staggered its implementation:

• Small electrical household appliances – July 4, 2022
• Large electrical household appliances – October 2, 2022
• Telecommunications and information technology equipment – December 31, 2022
• Lighting equipment – March 31, 2023
• Electrical and electronic tools and equipment – June 29, 2023
• Toys, entertainment devices and tools, sports equipment – September 27, 2023
• Tools for monitoring, measuring and controlling – December 26, 2023

Compliance

Suppliers should be able to exercise a certain level of freedom when choosing their route to compliance.

Options include conducting conformity testing actions on any of the following:

• All EEE components
• At least three critical EEE components – based on IEC 63000 risk analysis to identify critical electronic components
• Raw materials

SASO has posted a complete list of RoHS-related standards on its website. However, some of the most relevant standards, that may serve as a guide for suppliers, are:

• IEC 63000: Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances
• SASO IEC 62321: Electrotechnical products – Determination of levels of six regulated substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers)
• IEC 62474: Material declaration for products of and for the electrotechnical industry
• SASO IEC TR 62476: Guidance for evaluation of product with respect to substance-use restrictions in electrical and electronic products

EU RoHS versus Saudi RoHS

While both RoHS share the same objectives – to restrict the use of certain hazardous substances in EEE – the two regulations differ in what chemicals are restricted and the manner of proving compliance. The EU directive currently restricts the use of ten substances. In addition to the Saudi list, the EU also regulates bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP).

Both regulations also require a technical file to be created prior to the preparation and issuing of the Declaration of Conformity (DoC). However, EU regulations require the supplier to maintain it, with ready access to it by local market surveillance authorities. Saudi RoHS is different and requires the technical file to be compiled and reviewed for compliance by an SASO-notified CAB prior to the DoC being written and issued. As with EU RoHS, the technical file must be shown to market surveillance authorities upon demand.

It is foreseen that in the near future, both RoHS regulations will be ‘harmonised’, or at least have a semblance of mutuality between them. 

SGS solution

SGS provides a comprehensive range of testing and certification services to help manufacturers and exporters access complex EEE markets in Saudi Arabia. Its product specialists review verification reports from laboratory tests, physical inspections, factory audits, etc. to ensure compliance with pre-export verification of conformity (PVoC) requirements, including RoHS. In the end, a product is only trusted because it’s tested.