Compliance

RoHS Directive

EU directive limiting ten hazardous substances in electrical and electronic equipment sold in the Union.

Aliases: RoHS, Directive 2011/65/EU, Restriction of Hazardous Substances, 有害物质限制指令

The rule in one paragraph

RoHS, Directive 2011/65/EU, restricts the use of ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, two brominated flame retardants, and four phthalates. Maximum concentrations are set by weight in homogeneous materials, not in the finished product.

That last point is where most findings come from. A product can average below the limit while a single solder joint, cable jacket or coating exceeds it.

Scope

The directive covers equipment that needs electric currents or electromagnetic fields to function, plus equipment for generating and measuring such currents. Since the 2018 open-scope revision, most consumer electronics and electrical accessories are in scope, with defined exclusions such as military equipment.

Categories include large household appliances, small household appliances, IT and telecommunications equipment, consumer equipment, lighting, electrical tools, toys and monitoring instruments.

Compliance route

RoHS is a CE marking directive. The manufacturer performs the conformity assessment, compiles the technical file and issues a declaration of conformity that references RoHS. Testing is not the only permitted route, but most suppliers rely on material declarations plus targeted analytical testing.

Evidence that holds up includes:

A bill of materials with material declarations per component
Test reports from an accredited laboratory covering all ten substances
A declaration of conformity listing the directives applied
A technical file held by the EU responsible person

Exemptions

Annex III and Annex IV list time-limited exemptions, for example certain lead-containing alloys and solders. Exemptions are renewed, amended and withdrawn periodically. A supplier citing an exemption should be able to name the entry number and check that it is still valid.

Interaction with other rules

RoHS and REACH overlap but are not interchangeable: REACH covers a wider substance set and non-electrical articles, while RoHS sets specific limits for electrical equipment. WEEE handles end-of-life collection for the same products, and CE marking is the visible declaration that RoHS has been assessed. The GPSR adds general safety duties.

Primary source: Directive 2011/65/EU, Annexes II, III and IV.

FAQ

Which substances does RoHS restrict?

Ten substances: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers, and four phthalates (DEHP, BBP, DBP, DIBP).

Are the limits measured on the whole product?

No. Limits apply to homogeneous materials, meaning a material of uniform composition such as a solder alloy, a cable jacket or a coating. Averaging across the product is not allowed.

Does RoHS apply to batteries?

The Battery Regulation sets its own substance limits. RoHS applies to the electrical equipment around the battery, and both sets of rules can apply to the same product.

Can an exemption make a non-compliant part acceptable?

Only if the specific application is listed in Annex III or IV and the exemption is currently valid. Exemptions are time-limited and periodically revised.

How is RoHS proven to a marketplace?

Marketplaces typically ask for the declaration of conformity and a test report covering the ten substances for the shipped model. The documents must match the SKU, including model number and factory.