RoHS stands for the Restriction of Hazardous Substances. It is an EU directive that keeps certain toxic substances out of electrical and electronic equipment, from phones and kettles to cables and spare parts. If a restricted substance is present above the legal limit in any part of the product, that product cannot be sold in the EU.
The current text is Directive 2011/65/EU, often called RoHS 2. A 2015 amendment added four phthalates to the list, which is why some people call the current version RoHS 3. RoHS is one of the rules a product must meet before the manufacturer can sign the EU declaration of conformity and apply the CE marking.
The restricted substances and limits
Annex II of the Directive lists ten substances. The limits apply to each homogeneous material, meaning a single material that cannot be split mechanically, such as a solder joint, a plastic housing or a cable coating.
| Substance | Maximum concentration |
|---|---|
| Lead | 0.1% |
| Mercury | 0.1% |
| Cadmium | 0.01% |
| Hexavalent chromium | 0.1% |
| Polybrominated biphenyls (PBB) | 0.1% |
| Polybrominated diphenyl ethers (PBDE) | 0.1% |
| DEHP, BBP, DBP and DIBP (phthalates) | 0.1% each |
Annexes III and IV list exemptions for specific uses where no workable alternative exists yet. Each exemption has its own expiry date, so a product that complies today may need a redesign when an exemption it relies on ends.
Who it applies to
RoHS covers all electrical and electronic equipment, including cables and spare parts, unless the Directive explicitly excludes it. Since 22 July 2019 the scope has been open: any product that needs electricity to fulfil at least one intended function is in scope by default.
The obligations fall on each economic operator in the chain:
- Manufacturers make sure the product complies, keep technical documentation, draw up the declaration of conformity and affix the CE marking.
- Importers check that the manufacturer has done this before placing the product on the market.
- Distributors check for the CE marking and stop selling products they have reason to think do not comply.
How RoHS relates to other substance rules
RoHS sits alongside REACH, the EU's general chemicals regulation. REACH requires suppliers to tell their customers when an article contains a substance of very high concern (SVHC) above 0.1%, and to notify such articles to ECHA's SCIP database. A single electronic product often has to meet RoHS, REACH and the WEEE rules on extended producer responsibility at the same time.
Under ESPR, the Digital Product Passport for a product group can also require information on substances of concern. Substance data you collect for RoHS is the starting point for that.
How to prepare
- Map your materials. Build a bill of materials down to the component level so you know which homogeneous materials are in each product.
- Collect supplier declarations. Ask suppliers for RoHS declarations and, where risk is higher, material declarations or lab test reports.
- Check exemptions. Record which Annex III or IV exemptions you rely on and when they expire.
- Keep the technical file current. EN IEC 63000 is the harmonized standard for RoHS technical documentation. Keep the file and declaration for 10 years after the product is placed on the market.
- Re-check when parts change. A new supplier or component can bring a restricted substance back in.
How Veribl helps
Veribl checks each electrical product against RoHS and REACH and lists the substance data still missing. Suppliers answer substance requests and upload test reports through the supplier portal, and every answer is signed and kept exactly as it was sent, ready for your technical file and Digital Product Passport.
See the Veribl supplier portalOfficial sources
Frequently asked questions
What are the 10 RoHS substances?
Lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE), each limited to 0.1% by weight; cadmium, limited to 0.01%; and four phthalates, DEHP, BBP, DBP and DIBP, each limited to 0.1%. The limits apply to each homogeneous material, not to the whole product.
Which products fall under RoHS?
All electrical and electronic equipment that depends on electric current or electromagnetic fields to work, including cables and spare parts. Since 22 July 2019 the scope has been open, so any such equipment is covered unless the Directive specifically excludes it, for example large-scale fixed installations, means of transport or certain military equipment.
What is the difference between RoHS and REACH?
RoHS restricts a short list of substances in electrical and electronic equipment only. REACH is the general EU chemicals regulation: it covers all products and, among other things, requires suppliers to tell customers when an article contains a substance of very high concern above 0.1%. Many electronic products must meet both.
How do you prove RoHS compliance?
The manufacturer keeps technical documentation, usually built on supplier declarations, material data and test reports following EN IEC 63000, draws up an EU declaration of conformity and affixes the CE marking. The documentation and declaration must be kept for 10 years after the product is placed on the market.
What is a RoHS exemption?
Annexes III and IV list specific uses where a restricted substance is still allowed because there is no workable alternative yet, such as lead in certain alloys or solders. Each exemption has a scope and an expiry date, so manufacturers need to track when the exemptions they rely on end or get renewed.
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