Standards Comparison

    RoHS

    Mandatory
    2011

    EU regulation restricting hazardous substances in EEE

    VS

    CAA

    Mandatory
    1970

    U.S. federal law for air quality and emission standards

    Quick Verdict

    RoHS restricts hazardous substances in EEE for EU market access, while CAA regulates US air emissions via NAAQS and permits. Companies adopt RoHS for global sales compliance; CAA to avoid fines and ensure operational permits.

    Hazardous Substances

    RoHS

    Directive 2011/65/EU (RoHS 2)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Homogeneous material thresholds: 0.1% most substances, 0.01% cadmium
    • Restricts ten specific hazardous substances in EEE
    • Open scope: all EEE unless specifically excluded
    • Time-limited exemptions via delegated directives
    • Requires technical file and EU Declaration of Conformity
    Air Quality

    CAA

    Clean Air Act (42 U.S.C. §7401 et seq.)

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    18-24 months

    Key Features

    • National Ambient Air Quality Standards (NAAQS)
    • State Implementation Plans (SIPs) and nonattainment rules
    • New Source Performance Standards (NSPS)
    • Title V operating permits for major sources
    • Multi-layered enforcement and penalties

    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) to protect health and environment during waste management. It uses an open-scope approach applying to all EEE unless excluded, with restrictions at the homogeneous material level.

    Key Components

    • Ten restricted substances: Pb, Cd, Hg, Cr(VI), PBB, PBDE, DEHP, BBP, DBP, DIBP.
    • Thresholds: 0.1% w/w for most, 0.01% for Cd in homogeneous materials.
    • Annex III/IV time-limited exemptions renewed via delegated acts.
    • Compliance model: technical documentation per EN IEC 63000, EU Declaration of Conformity (DoC), CE marking.

    Why Organizations Use It

    • Mandatory for EU/EEA market access, avoiding fines, recalls, bans.
    • Improves recyclability, supply chain governance, ESG alignment.
    • Manages risks from decentralized enforcement, exemption expiries.
    • Builds stakeholder trust, enables global market competitiveness.

    Implementation Overview

    Phased: scoping products, gap analysis on BoMs, supplier declarations, tiered testing (IEC 62321), technical file assembly. Applies to EEE manufacturers/importers/distributors across industries; SMEs to enterprises. No certification body, but 10-year retention for market surveillance audits; typically 6-18 months.

    CAA Details

    What It Is

    The Clean Air Act (CAA), codified at 42 U.S.C. §7401 et seq., is the primary U.S. federal statute regulating air emissions from stationary and mobile sources to protect public health and welfare. It uses **cooperative federalismEPA sets national standards; states implement via plans and permits.

    Key Components

    • NAAQS for six criteria pollutants (ozone, PM, CO, Pb, SO2, NO2) with primary/secondary forms.
    • SIPs and nonattainment planning (infrastructure, pollutant-specific).
    • Technology standards: NSPS, NESHAPs/MACT for HAPs.
    • Title V operating permits consolidating requirements.
    • Titles II, IV, VI for mobile sources, acid rain trading, ozone protection. Enforceable via monitoring, reporting; no certification but federal oversight.

    Why Organizations Use It

    Mandatory compliance avoids penalties, sanctions, FIPs. Manages nonattainment risks, supports capital planning, ESG goals; enables market-based trading.

    Implementation Overview

    Phased: applicability assessment, permitting (Title V/NSR), controls/monitoring (CEMS), reporting (CEDRI/ECMPS). Applies to major sources nationwide; ongoing audits, state variations.

    Key Differences

    Scope

    RoHS
    Hazardous substances in EEE materials
    CAA
    Air quality and emissions from sources

    Industry

    RoHS
    EEE manufacturers, global with regional variants
    CAA
    All industries with air emissions, US-focused

    Nature

    RoHS
    EU product restriction directive, mandatory
    CAA
    US federal air pollution statute, mandatory

    Testing

    RoHS
    XRF screening, IEC 62321 lab confirmation
    CAA
    CEMS monitoring, stack testing, QA protocols

    Penalties

    RoHS
    Decentralized MS fines, product withdrawal
    CAA
    Civil penalties up to millions, sanctions

    Frequently Asked Questions

    Common questions about RoHS and CAA

    RoHS FAQ

    CAA FAQ

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