Detailed Explanation of the EU RoHS 2.0 Testing Procedure for Motor Brushes
Date：2025-11-26 10:34:20 Classification
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The RoHS Directive is a mandatory standard established by EU legislation. It is the "Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment." The EU RoHS 2.0 testing process for motor brushes can be divided into six standard steps, among which sample disassembly and key substance testing are crucial steps to ensure compliance.
Step 1: Defining the Scope of Testing and Sample Preparation
1. Defining the Testing Object
- Complete motor brush assembly (including carbon brush body, metal connectors, wires, and plastic housing)
- Components requiring separate testing:
Carbon brush substrate (may contain lead or cadmium)
Metal leads (hexavalent chromium in the plating)
Connecting wires (phthalates in the PVC insulation layer)
Plastic support (flame retardants PBB/PBDE)
2. Sample Quantity Requirements
- Provide 5-10 complete brushes from the same batch (to ensure representativeness)
- If brushes are of different materials or colors, separate samples must be submitted.
Step 2: Selecting a Certification Body and Submitting the Application
1. Certification Body Qualification Requirements
- Must possess EU-recognized EN ISO/IEC 17025 laboratory accreditation (e.g., DEZEW Testing CNAS registration number: L8083)
- Must clearly state the purpose of the testing (e.g., export customs clearance, customer factory audit, or CE certification support)
2. List of Application Materials
- Product Specifications (including material composition description)
- Simplified Production Process Flowchart (highlighting electroplating, welding, and other processes)
- Basic Company Information (Business License, Contact Person Information)
Step 3: Core Testing Items and Methods (for motor brushes)
| Detected Substances | Limit Requirements | Testing Standard Methods
| Lead (Pb) | ≤0.1% (1000mg/kg) | IEC 62321-4:2013
| Cadmium (Cd) | ≤0.01% (100mg/kg) | IEC 62321-5:2013
| Hexavalent Chromium (Cr⁶⁺) | ≤0.1% (1000mg/kg) | IEC 62321-7:2015
| Polybrominated Biphenyls (PBBs) | ≤0.1% (1000mg/kg) | IEC 62321-8:2017
| Phthalate Esters (DEHP and 4 other items) | ≤0.1% (1000mg/kg) | IEC 62321-10:2015
Key Note: Graphite components in carbon brushes may interfere with lead detection results; accurate quantitative analysis using ICP-MS is required (XRF screening is only a preliminary screening method).
Step Four: Laboratory Testing Procedure
1. Pretreatment Stage (approximately 2 working days)
- Physical Separation: Mechanical separation of components of different materials (to avoid cross-contamination)
- Chemical Pretreatment:
- Metal Components: Microwave digestion (nitric acid + hydrofluoric acid system)
- Plastic Components: Soxhlet extraction (for organic pollutants)
2. Instrumental Analysis Stage (3-5 working days)
- Heavy Metal Detection: ICP-MS (Inductively Coupled Plasma Mass Spectrometry)
- Organic Pollutants: GC-MS (Gas Chromatography-Mass Spectrometry)
- Hexavalent Chromium Special Project: Spectrophotometry (DIN EN 15205 Standard)
3. Data Review and Report Preparation (1-2 working days)
- Test data must meet CNAS laboratory quality control requirements (parallel sample deviation ≤10%)
- The report must include: sample photos, dissection spectra, raw data, and compliance determination.
Step Five: Report Review and Rectification (If Non-compliant)
1. Common Non-compliant Items and Solutions
- Cadmium Exceeding Standard: Replace with cadmium-free electroplating process (using cyanide-free zinc plating as a substitute)
- Phthalate Exceeding Standard: Replace PVC insulation with silicone or TPU material
- Hexavalent Chromium Exceeding Standard: Use chromium-free passivation treatment for metal parts
Step Six: Obtaining the Report and Compliance Declaration
1. Report Validity Confirmation
- The test report must include the laboratory's CNAS stamp.
- Report Validity: Usually 1 year (extendable if there are no changes in production process or raw materials)
2. Subsequent Compliance Maintenance
- Maintain complete testing records (including raw data and spectra) for at least 10 years.
- Retesting of key items is required for each batch of raw materials (e.g., when changing carbon brush suppliers).
Overall cycle and cost reference:
| Process Stage | Time Consumption | Cost Range (RMB)
| Sample Preparation and Application | 1-2 days | None
| Testing Implementation | 5-7 days | 800-2000 RMB
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