RoHS
EU regulation restricting hazardous substances in EEE
AS9110C
Aerospace standard for MRO quality management systems.
Quick Verdict
RoHS restricts hazardous substances in electronics for EU market access, while AS9110C certifies quality management for aerospace MRO safety. Companies adopt RoHS for compliance and recyclability, AS9110C for contracts and airworthiness assurance.
RoHS
Directive 2011/65/EU (RoHS 2) on hazardous substances
Key Features
- Homogeneous material thresholds limit 10 substances to 0.1%
- Open-scope applies to all EEE unless excluded
- Time-limited exemptions require active lifecycle tracking
- Mandates technical documentation and EU Declaration of Conformity
- Tiered testing via IEC 62321 screening and confirmation
AS9110C
AS9110C Quality Management Systems for Aviation Maintenance
Key Features
- Risk-based thinking embedded in planning and operations
- Counterfeit parts prevention and detection controls
- Configuration management for airworthiness traceability
- Maintenance release and human factors requirements
- Project management for MRO service delivery
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
RoHS Details
What It Is
Directive 2011/65/EU (RoHS 2) is an EU regulation restricting hazardous substances in electrical and electronic equipment (EEE). It aims to protect health and environment by limiting risks in waste management, using maximum concentration values (MCVs) in homogeneous materials—smallest mechanically separable units like solders or coatings.
Key Components
- **10 restricted substancesPb, Hg, Cd, Cr(VI), PBB, PBDE, DEHP, BBP, DBP, DIBP (0.1% limit, Cd at 0.01%).
- **Annexes III/IV exemptionsTime-limited for specific uses.
- **Open scopeAll EEE unless excluded (e.g., large fixed installations).
- **Compliance modelRisk-based via EN IEC 63000 documentation, IEC 62321 testing.
Why Organizations Use It
Mandated for EU market access; prevents recalls, fines. Drives supply chain governance, recyclability, ESG benefits, level playing field.
Implementation Overview
Phased: scope products, gap analysis BoMs, supplier declarations, tiered testing (XRF screening, ICP-MS confirmation), technical files/DoC. Applies globally to EEE sellers; 6-18 months typical, no certification but 10-year retention for audits.
AS9110C Details
What It Is
AS9110C (AS9110:2016 Rev C) is the international quality management system (QMS) standard for aviation maintenance, repair, and overhaul (MRO) organizations. It builds on ISO 9001:2015 using the High-Level Structure (HLS) and incorporates aerospace-specific requirements for safety-critical processes. Primary purpose: ensure consistent delivery of airworthy products/services via risk-based thinking (RBT) and PDCA cycles.
Key Components
- Core clauses 4-10 covering context, leadership, planning, support, operation, evaluation, improvement.
- Aviation additions: configuration management, counterfeit parts prevention, human factors, maintenance release controls.
- Built on ISO 9001 with ~30 supplemental requirements; voluntary certification via accredited bodies.
Why Organizations Use It
- Meets customer/OEM contracts, regulatory alignment (FAA/EASA Part-145).
- Mitigates safety/liability risks, reduces rework/downtime.
- Enables market access (OASIS listing), boosts efficiency (5-12% cost savings), builds stakeholder trust.
Implementation Overview
- Phased: gap analysis, process design, training, audits, certification (6-12 months typical).
- Targets MROs globally; requires operational evidence (3+ months data) for audits.
Key Differences
| Aspect | RoHS | AS9110C |
|---|---|---|
| Scope | Hazardous substances in EEE materials | QMS for aviation MRO processes |
| Industry | Electronics manufacturing, global | Aerospace maintenance organizations |
| Nature | EU product restriction directive | Voluntary QMS certification standard |
| Testing | XRF screening, IEC 62321 lab analysis | Internal audits, management reviews |
| Penalties | Fines, recalls by Member States | Loss of certification, no legal fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about RoHS and AS9110C
RoHS FAQ
AS9110C FAQ
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