UAE to carry out RoHS-like regulation

World Trade Organization (WTO) issued Notification No. G/TBT/N/ARE/265 on 3 August 2015. According to Emirates control scheme to restrict the use of hazardous materials in electronic and electrical devices (UAE RoHS), the content is similar to RoHS 2.0 in EU and the ten restricted substances and limits are the same, even the effective date for the four restrictions on phthalates. In the meanwhile, the legislation sets forth that producers should provide test reports for conformity assessment.

Substance	Limit/(w/w)	Effective date	Scope	Exemption
Cadmium (Cd)	0.01%	The products available in the market before the date of the publication are allowed to sell until 1st of January 2018; Medical devices, in vitro diagnostic medical devices, monitoring and control instruments, industrial monitoring and control instruments placed on the market before 01 January 2020	1. Large household appliances 2. Small household appliances 3. IT and telecommunication equipment 4. Consumer equipment 5. Lighting equipment 6. Electrical and electronic tools (with the exception of large-scale stationary industrial tools) 7. Toys leisure and sport equipment 8. Medical devices (with the exception of all implanted and infected products) 9. Monitoring and control instruments including industrial monitoring and control instrument 10. Automatic dispensers 11. Other EEE not covered by any of the categories above	Yes
Mercury (Hg)	0.1%
Lead (Pb)	0.1%
Hexavalent chromium (Cr (VI))	0.1%
Polybrominated biphenyls (PBBs)	0.1%
Polybrominated biphenyl ethers (PBDEs)	0.1%
Bis(2-ethylhexyl) phthalate (DEHP)	0.1%	22 July 2019: Excluding medical devices and monitoring and control instruments; 22 July 2021: Medical devices, including in vitro medical devices, and monitoring and control instruments, including industrial monitoring and control instruments.
Butyl benzyl phthalate (BBP)	0.1%
Dibutyl phthalate (DBP)	0.1%
Diisobutyl phthalate (DIBP)	0.1%

Annex 6 hereof also lists applicable standards for UAE RoHS.

Standard Edition	Name
IEC 62321 Edition 1.0 2008-12	Electrotechnical products – Determination of levels of six regulated substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers)
IEC 62474 Edition 1.0 2012-03	Material declaration for products of and for the electrotechnical industry
IEC/TR 62476 Edition 1.0 2010-02	Guidance for evaluation of products with respect to substance-use restrictions in electrical and electronic devices
IEC 50581: 2012	Technical documentation for the assessment of electrical and electronic devices with respect to the restriction of hazardous substances

Similar with EU REACH, UAE RoHS also lists the exemptions for all electrical and electronic devices and special clauses for exemption applicable to medical and monitoring instruments in Annex 3 and Annex 4.

The legislation sets forth that producers should provide test report, general description of products, product design and other detailed information, technical documents such as technical compliance list for UAE list before conformity assessment. Suppliers should register UAE conformity assessment plan within a year since the publishing date of legislation on the Official Journal. Products cannot be intended for sale in UAE if not registered or without quality identification, otherwise suppliers must be responsible for the non-compliant products.

Any infringement of the legislation will be punished and suppliers should recall the products from the market and return them to the place of manufacture. ESMA or other competent authorities will take other measures if they think it necessary.

The implementation of UAE RoHS will not only exert great influence on producers of electrical and electronic devices and can also be imitated as a regional technical barrier in the other Middle East countries in light of the status of UAE in Gulf Cooperation Council (GCC).

Reminder: UAE RoHS clearly sets forth the responsibilities and obligations for suppliers and producers and related companies should deal with it in advance. On the one hand, track the new regulation and improve supply chains for accessories and materials according to correspondent requirements so as to ensure safety and green requirements for electrical intended for export; on the other hand, register certifications as per market requirements and choose authoritative testing lab to issue compliant test report so as to avoid trade barriers.