What is the RoHS Directive and what products does it cover?

The RoHS Directive (Restriction of Hazardous Substances - 2011/65/EU as amended by 2015/863) restricts the use of specific hazardous materials in electrical and electronic equipment (EEE). It covers all EEE with a voltage rating up to 1000V AC or 1500V DC, including consumer electronics, IT equipment, lighting, toys with electrical functions, medical devices, and monitoring instruments.

What substances are restricted under RoHS?

RoHS restricts 10 substances: Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium (Cr6+), Polybrominated Biphenyls (PBB), Polybrominated Diphenyl Ethers (PBDE), and four phthalates added in 2019 - DEHP, BBP, DBP, and DIBP. Maximum concentration values are 0.1% by weight for most substances and 0.01% for cadmium, measured in homogeneous materials.

What is a homogeneous material under RoHS?

A homogeneous material is one that cannot be mechanically separated into different materials. Examples include individual types of plastic, ceramic, glass, metal, alloy, paper, board, resins, and coatings. The RoHS limits apply to each homogeneous material separately, not to the whole product or component. For example, solder in a circuit board is tested separately from the plastic casing.

Do I need to test every product for RoHS compliance?

Testing every product isn't required by law, but you must have evidence of compliance. This typically includes supplier declarations, material composition data, and test reports for high-risk materials. A risk-based approach is recommended: test products from new suppliers, high-risk categories (cables, plastics, coatings), and conduct periodic verification testing. XRF screening followed by wet chemistry confirmation is the standard testing approach.

What are RoHS exemptions and how do I know if they apply?

RoHS exemptions allow restricted substances in specific applications where technically unavoidable or where substitutes would cause more harm. Exemptions are listed in Annexes III and IV and are time-limited—typically 5-7 years with possible renewal. Common exemptions include lead in high-melting-temperature solders and mercury in certain lamp types. You must document which exemptions apply to your products and monitor for expiration dates.

What documentation do I need for RoHS compliance?

You need: (1) Technical documentation including bill of materials with substance information, (2) Supplier declarations confirming RoHS compliance for components, (3) Test reports for verification (especially for high-risk materials), (4) EU Declaration of Conformity stating RoHS compliance, and (5) Records of any applicable exemptions. Documentation must be kept for 10 years after the last product is placed on the market.

How does RoHS relate to CE marking?

RoHS is part of CE marking requirements for electrical and electronic equipment. If your product requires CE marking and falls under RoHS scope, you must include RoHS in your Declaration of Conformity alongside other applicable directives (like LVD, EMC, RED). The CE mark on your product indicates compliance with all applicable directives including RoHS.

Are spare parts and cables covered by RoHS?

Yes, spare parts, cables, and accessories are covered by RoHS if they are EEE or are essential for the function of EEE. Cables with electrical functionality, power adapters, and replacement components must all comply with RoHS. The only exception is spare parts for equipment placed on the market before RoHS applied to that category.

What happens if my product doesn't comply with RoHS?

Non-compliant products cannot legally be placed on the EU market. Consequences include: customs refusal and seizure at borders, market surveillance action and recalls, removal from online marketplaces, fines (up to €100,000+ depending on member state), and potential criminal liability for serious violations. Amazon and other platforms actively enforce RoHS for electronics categories.

How do I handle the 2019 phthalate restrictions?

Four phthalates (DEHP, BBP, DBP, DIBP) were added to RoHS with a limit of 0.1% each in homogeneous materials. These are commonly found in plasticized PVC—cables, wire insulation, soft plastic parts. Ensure suppliers have transitioned to phthalate-free alternatives and request specific declarations covering these substances. Products placed on the market before July 22, 2019 (or July 22, 2021 for medical devices and monitoring instruments) were exempt.

EU Directive

Electronics

20 min read

RoHS Directive Guide

The RoHS Directive restricts hazardous substances in electrical and electronic equipment to protect human health and the environment. This comprehensive guide covers all 10 restricted substances, product scope, exemptions, testing requirements, and compliance documentation for electronics sold in the EU market.

What is the RoHS Directive?

RoHS (Restriction of Hazardous Substances) Directive 2011/65/EU, as amended by Directive (EU) 2015/863, restricts the use of specific hazardous materials found in electrical and electronic products. The directive aims to reduce environmental contamination from electronic waste and protect assembly workers and consumers from toxic substances.

Originally introduced in 2006 with six restricted substances, RoHS was updated in 2011 (RoHS 2) to expand scope and align with CE marking requirements, and again in 2015 to add four phthalates. The current directive restricts 10 substances with maximum concentration limits in "homogeneous materials"—materials that cannot be mechanically separated into different materials.

RoHS is integral to CE marking for electronics. Products requiring CE marking that fall within RoHS scope must demonstrate compliance through technical documentation and include RoHS in their EU Declaration of Conformity. Non-compliance prevents legal market access and can result in products being seized at customs or removed from sale.

For e-commerce sellers, RoHS compliance is actively enforced by platforms like Amazon, which may request test reports and declarations for electronics products. Market surveillance authorities also conduct testing programs, and non-compliant products face recalls, fines, and reputational damage.

10 Restricted Substances Under RoHS

Substance	Limit	Common Sources	Category
Lead (Pb)	0.1%	Solder, glass, ceramics, PVC stabilizers, brass/bronze alloys	Original 6
Mercury (Hg)	0.1%	Switches, relays, lamps, batteries, LCD backlights	Original 6
Cadmium (Cd)	0.01%	Batteries, pigments, plating, PVC stabilizers, contacts	Original 6
Hexavalent Chromium (Cr6+)	0.1%	Corrosion coatings, pigments, leather tanning	Original 6
PBB (Polybrominated Biphenyls)	0.1%	Flame retardants in plastics, textiles	Original 6
PBDE (Polybrominated Diphenyl Ethers)	0.1%	Flame retardants in plastics, circuit boards, cables	Original 6
DEHP (Bis(2-ethylhexyl) phthalate)	0.1%	PVC plasticizer, cables, wire insulation	Phthalates (2019)
BBP (Butyl benzyl phthalate)	0.1%	PVC flooring, synthetic leather, cables	Phthalates (2019)
DBP (Dibutyl phthalate)	0.1%	PVC, adhesives, printing inks, lacquers	Phthalates (2019)
DIBP (Diisobutyl phthalate)	0.1%	PVC, adhesives, lacquers, cellulose plastics	Phthalates (2019)

Note: Limits are maximum concentration values (% by weight) in homogeneous materials. The 0.01% limit for cadmium is 10x stricter than other substances due to its extreme toxicity.

Products Within RoHS Scope

RoHS applies to all electrical and electronic equipment (EEE) with a voltage rating up to 1000V AC or 1500V DC. This includes 11 product categories covering virtually all electronics:

Large Household Appliances

RefrigeratorsWashing machinesOvens

Small Household Appliances

Vacuum cleanersToastersCoffee makers

IT and Telecommunications

ComputersPhonesPrinters

Consumer Equipment

TVsAudio systemsCameras

Lighting Equipment

LED lampsFluorescent fixturesDecorative lighting

Electrical and Electronic Tools

DrillsSawsSoldering irons

Toys and Sports Equipment

Electric trainsVideo gamesSlot cars

Medical Devices

Diagnostic equipmentTherapeutic devicesIn vitro diagnostics

Monitoring and Control Instruments

ThermostatsSmoke detectorsIndustrial monitoring

Important: Cables and Spare Parts

Cables, power adapters, and spare parts are explicitly within scope if they have electrical functionality. This is a common compliance gap—ensure all accessories and replacement parts also meet RoHS requirements.

RoHS Exemptions

RoHS allows exemptions for applications where restricted substances are technically unavoidable or where alternatives would have greater negative impacts. Exemptions are listed in Annexes III and IV and are time-limited. If you use exempted applications, you must document them in your technical file.

6(a) - Lead in high melting temperature solders

Ongoing review

Lead in solders with >85% lead content

Application: High-reliability electronics, servers, infrastructure

6(b) - Lead in solders for servers/storage

Ongoing review

Lead solder for servers, storage systems, network infrastructure

Application: Enterprise IT equipment

6(c) - Lead in solders for network equipment

Ongoing review

Lead solder for network infrastructure equipment

Application: Telecom and network infrastructure

7(a) - Lead in glass of CRTs

Expired for most applications

Lead in glass of cathode ray tubes

Application: Legacy display technology

7(c-I) - Lead in glass/ceramic

Ongoing review

Lead in glass or ceramic parts except dielectric ceramics

Application: Optical components, piezoelectric devices

8(b) - Cadmium in electrical contacts

Most expired, limited applications remain

Cadmium and its compounds in electrical contacts

Application: High-reliability switches

9(b) - Lead in PZT ceramics

Ongoing review

Lead in PZT-based dielectric ceramic materials

Application: Sensors, actuators, transducers

15 - Lead in solders for flip chip

Ongoing review

Lead in solders for flip chip packages

Application: Advanced semiconductor packaging

Exemption Management: Exemptions have expiration dates and are regularly reviewed. Monitor exemption renewal decisions and plan for alternatives before expiration. Document all exemptions used in your technical file with justification.

RoHS Testing Methods

XRF Screening

X-Ray Fluorescence for rapid elemental screening of solid samples

Best For:

Initial screening, incoming inspection, large volume testing

Limitations:

Cannot distinguish chemical forms (e.g., Cr vs Cr6+), surface measurement only

Accuracy:

Semi-quantitative, requires confirmation for borderline results

ICP-OES/ICP-MS

Inductively Coupled Plasma for precise elemental quantification

Best For:

Confirmation testing, certification, accurate concentration determination

Limitations:

Destructive, requires sample preparation, more expensive

Accuracy:

Highly quantitative, reference method for metals

UV-Vis Spectroscopy

For hexavalent chromium determination via diphenylcarbazide method

Best For:

Specific Cr6+ quantification in extracted samples

Limitations:

Requires extraction, specific to chromium speciation

Accuracy:

Quantitative for Cr6+, ISO 17075 standard method

GC-MS

Gas Chromatography-Mass Spectrometry for organic compounds

Best For:

Phthalates, PBB, PBDE determination

Limitations:

Requires extraction and sample preparation

Accuracy:

Quantitative, reference method for organic restricted substances

7-Step RoHS Compliance Process

Determine Product Scope

Verify your product falls within RoHS scope—electrical/electronic equipment with voltage up to 1000V AC or 1500V DC.

Confirm product requires electricity to function
Check product against 11 equipment categories
Identify any exclusions that may apply
Document scope determination rationale

Create Bill of Materials

Develop a comprehensive BOM identifying all components, materials, and potential sources of restricted substances.

List all components and subassemblies
Identify homogeneous materials in each component
Flag high-risk materials (solder, plastics, coatings)
Map supply chain for component traceability

Collect Supplier Declarations

Obtain RoHS compliance declarations from all component and material suppliers.

Request RoHS declarations from all suppliers
Verify declarations cover all 10 substances
Confirm declarations reference correct standards
Document any claimed exemptions

Verify with Testing

Conduct verification testing on high-risk components and materials using XRF screening and wet chemistry.

Identify high-risk components for testing
Conduct XRF screening as initial check
Perform wet chemistry analysis if XRF indicates concern
Document all test results and methodology

Document Exemptions

If using any exemptions, document the specific exemption, its application, and expiration date.

Identify applicable Annex III/IV exemptions
Document exemption justification per component
Track exemption expiration dates
Plan for exemption phase-out where possible

Prepare Technical Documentation

Compile technical file demonstrating RoHS compliance including material data, declarations, and test reports.

Assemble component compliance evidence
Include test reports and supplier declarations
Document conformity assessment process
Keep records for 10 years post-market

Issue Declaration of Conformity

Create EU Declaration of Conformity including RoHS alongside other applicable directives.

Reference Directive 2011/65/EU (as amended)
Include alongside LVD, EMC, and other directives
Sign by authorized representative
Make available with product documentation

RoHS Declaration of Conformity

For products within RoHS scope, the EU Declaration of Conformity must reference Directive 2011/65/EU (as amended). This is typically combined with declarations for other applicable directives like LVD and EMC.

Required Elements

Manufacturer name and address
Product identification (name, type, model)
Statement of sole responsibility
Reference to Directive 2011/65/EU
Reference to harmonized standards used
Exemptions applied (if any)
Place and date of issue
Authorized signatory details

Technical Documentation

Product description and design data
Bill of materials with substance info
Supplier RoHS declarations
Test reports (XRF, wet chemistry)
Exemption documentation
Conformity assessment records
Risk assessment for substances
Quality control procedures

Common Non-Compliance Issues

Lead in solder joints

Cause: Using legacy leaded solder without valid exemption

Solution: Transition to lead-free solder (SAC305, etc.) or document exemption

Phthalates in PVC cables

Cause: Cables with plasticized PVC containing DEHP/DBP/BBP/DIBP

Solution: Source cables with alternative plasticizers, verify supplier declarations

Cadmium in plating/contacts

Cause: Using cadmium plating for corrosion resistance

Solution: Switch to zinc, nickel, or tin plating alternatives

Hexavalent chromium in coatings

Cause: Anti-corrosion treatments using chromate conversion coatings

Solution: Use trivalent chromium or chromium-free alternatives

Lead in brass components

Cause: Brass alloys containing >0.1% lead for machinability

Solution: Specify lead-free brass or use exemption 6(c) where applicable

PBDE in plastic housings

Cause: Legacy flame retardants in plastic components

Solution: Specify PBDE-free flame retardants in material specifications

Frequently Asked Questions

Related Guides

CE Marking Complete Guide

RoHS is part of CE marking requirements for electronics—see the full process.

REACH Compliance Guide

Additional chemical requirements applying to all products including electronics.

Selling electronics in the EU?

Use SellSafe to verify your electronics products meet RoHS and all other EU compliance requirements. Get clear guidance on documentation and testing needs.

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