RoHS

# RoHS RoHS, the Restriction of Hazardous Substances Directive (2011/65/EU), limits the use of hazardous substances in electrical and electronic equipment sold in the EU. It restricts ten substances, including lead, mercury, cadmium and certain phthalates, above defined thresholds, and it is a CE marking directive, meaning compliance is declared through the standard conformity assessment process. ## Key facts - RoHS is Directive 2011/65/EU, a recast that has applied since 2 January 2013. - It restricts ten substances in electrical and electronic equipment (EEE) placed on the EU market. - Maximum concentration values are 0.1 percent by weight for most substances and 0.01 percent for cadmium, measured in homogeneous materials. - The four phthalates DEHP, BBP, DBP and DIBP were added by Directive (EU) 2015/863, applying from 22 July 2019. - Eleven product categories are covered, including a catch-all category for other EEE. - Exemptions for specific technical applications are listed in Annexes III and IV and expire on defined dates. - Compliance is demonstrated through technical documentation per EN IEC 63000 and declared in the EU Declaration of Conformity. ## Scope: what counts as EEE RoHS applies to electrical and electronic equipment, defined as equipment dependent on electric currents or electromagnetic fields to fulfil at least one intended function. This covers large and small household appliances, IT and telecommunications equipment, consumer electronics, lighting, electrical tools, toys and leisure equipment, medical devices, monitoring and control instruments, and automatic dispensers, plus an eleventh catch-all category for other EEE not covered elsewhere. The directive operates on an open scope basis since 22 July 2019: all EEE falls within scope unless specifically excluded. Exclusions include military equipment, equipment designed to be sent into space, large-scale stationary industrial tools, large-scale fixed installations, means of transport other than electric two-wheel vehicles, non-road mobile machinery, active implantable medical devices, and photovoltaic panels for public, commercial, industrial and residential use. A product is EEE if electricity is needed for at least one intended function. A gas cooker with an electric ignition is EEE; a purely mechanical toy is not. Cables, spare parts and accessories intended for EEE are also in scope, which matters for aftermarket businesses. Where a product has both electrical and non-electrical functions, the electrical part brings it into scope. ## The ten restricted substances and thresholds The original six restricted substances were lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE), all limited to 0.1 percent, and cadmium, limited to 0.01 percent. Directive (EU) 2015/863, often called RoHS 3, added four phthalates used as plasticisers: DEHP, BBP, DBP and DIBP, each limited to 0.1 percent, with application from 22 July 2019 for most categories and 22 July 2021 for medical devices and monitoring and control instruments. Thresholds apply to homogeneous materials, meaning materials of uniform composition that cannot be mechanically separated into different materials, such as a plastic housing, a solder joint or a coating. A product complies only if every homogeneous material in it stays below the limits. This is stricter than it sounds: a single non-compliant coating on a screw can fail the whole product, which is why supply chain declarations must go down to the material level. Testing follows defined methods, principally the IEC 62321 series, which standardises sample preparation and analytical procedures for each substance. Screening by X-ray fluorescence (XRF) is common for initial checks, with wet chemical analysis for confirmation. Test reports should identify the homogeneous materials tested and the methods used, since market surveillance authorities assess exactly that. ## Exemptions: Annexes III and IV Because some applications have no technically or scientifically practicable substitute, RoHS provides exemptions. Annex III lists exemptions for general EEE, such as lead in certain solders, in glass and ceramics, and in specific alloys, each with defined scope and expiry dates. Annex IV lists exemptions specific to medical devices and monitoring and control instruments, recognising their longer development cycles and reliability requirements. Exemptions are time-limited and reviewed. When an exemption expires without renewal, the substance becomes restricted for that application, and products must be redesigned or reformulated. The Commission evaluates renewal applications on technical substitutability, and industry must apply well before expiry. Tracking exemption expiry dates for every substance-application combination in the bill of materials is a core RoHS management task. Using an exemption does not remove the documentation duty: the technical file must identify the exemption relied upon and show that the application falls within its scope. Claiming an exemption that does not quite fit the application is a common enforcement finding. ## Conformity assessment and documentation RoHS is a CE marking directive. The manufacturer carries out the conformity assessment, typically internal production control, draws up the technical documentation, signs the EU Declaration of Conformity covering RoHS alongside the other applicable directives, and affixes the CE marking. No notified body is involved in the standard route. The technical documentation standard is EN IEC 63000, which specifies what the file must contain: a general product description, the materials, parts and subassemblies identified, supplier declarations, the assessment of which materials are at risk, test results where used, and the evaluation of exemptions. The emphasis is on a documented due diligence process across the supply chain rather than on testing every finished product. Supplier declarations are the backbone. Manufacturers should obtain material declarations or full substance disclosures from suppliers, assess them for plausibility, and verify through risk-based testing. Declarations should reference the homogeneous material level and be refreshed when formulations or suppliers change. Importers and distributors have the usual verification duties: checking the CE marking, the declaration and the availability of documentation. | Substance | Limit (homogeneous material) | Common sources | |---|---|---| | Lead (Pb) | 0.1% | Solders, PVC stabilisers, alloys | | Mercury (Hg) | 0.1% | Lamps, switches, relays | | Cadmium (Cd) | 0.01% | Pigments, plating, contacts | | Hexavalent chromium (Cr VI) | 0.1% | Corrosion coatings, plating | | PBB | 0.1% | Flame retardants in plastics | | PBDE | 0.1% | Flame retardants in plastics | | DEHP | 0.1% | Plasticiser in PVC cables, gaskets | | BBP | 0.1% | Plasticiser in plastics | | DBP | 0.1% | Plasticiser in plastics | | DIBP | 0.1% | Plasticiser in plastics | ## RoHS around the world The EU directive inspired similar laws globally, but they differ in scope and detail. China RoHS requires marking of the environmental protection use period and disclosure of hazardous substance content, with a conformity assessment system for listed products. UK RoHS mirrors the EU directive in Great Britain. Other jurisdictions with RoHS-like rules include California, South Korea, Japan, India, Turkey, Ukraine and the Eurasian Economic Union, each with its own substance lists, thresholds, exemptions and marking requirements. A global product must therefore satisfy the strictest applicable combination, not just the EU directive. Substance lists largely overlap on the core six, but phthalate coverage, exemptions and documentation expectations vary. Companies typically build a global restricted substances programme with the EU RoHS as the baseline and market-specific add-ons, managed through a single bill-of-materials substance database. Enforcement is active. EU market surveillance authorities test EEE for RoHS compliance in coordinated campaigns, and non-compliant products face withdrawal and recall. Because RoHS failures are invisible to consumers, enforcement relies on documentation review and laboratory testing, which rewards companies with strong supplier declaration systems and punishes those without them. ## Frequently asked questions Does RoHS apply to batteries? Batteries are primarily governed by the [EU Batteries Regulation](/regulations/eu-batteries), which sets its own substance restrictions. Where a battery is part of EEE, RoHS still applies to the equipment, and the interaction should be assessed per product. What is a homogeneous material? A material of uniform composition throughout that cannot be mechanically disjointed into different materials. Examples include a plastic casing, a layer of paint, a solder joint or a metal plating. Limits apply at this level, not to the whole product. Do I need to test every product for RoHS? No. The standard approach under EN IEC 63000 is supplier declarations plus risk-based verification testing. Test high-risk materials and suppliers, new formulations and products with plausible exposure, and document the rationale. How do I handle an exemption that is expiring? Check the Commission's review status, submit or support a renewal application if substitution is not practicable, and run a parallel redesign programme. Do not assume renewal; expired exemptions mean immediate restriction. Does RoHS apply to second-hand EEE? RoHS applies to EEE placed on the market. Second-hand products already on the EU market before the requirements applied are generally outside scope for the placing that already occurred, but refurbished products placed on the market anew should be assessed. What is the difference between RoHS and REACH? RoHS restricts specific substances in EEE with fixed thresholds and is a CE marking directive. REACH is a broader chemicals framework covering registration, authorisation and restrictions across all sectors. A product must comply with both where each applies. ## Sources - EU RoHS Directive overview - EU harmonised standards overview - EU market surveillance framework