What Is RoHS Compliance? 

Restriction of Hazardous Substances (RoHS) compliance is about adhering to the RoHS Directive, which is a set of rules that regulates the use of harmful substances in electrical and electronic equipment (EEE). Its goal is to reduce the potential dangers these products pose to health and the environment.

Origin and scope of RoHS

The RoHS directive was introduced by the EU to reduce environmental and health risks caused by harmful substances in EEE. The first RoHS Directive (2002/95/EC) was adopted in 2003 and took effect in 2006. It was part of broader EU efforts to improve electronic waste management, aligning with the Waste Electrical and Electronic Equipment (WEEE) Directive.

RoHS was developed in response to concerns about toxic substances, like lead and mercury, leaching from discarded electronics into soil and water. These heavy metals pose serious risks to human health and ecosystems. 

Over time, the directive has evolved, with RoHS 2 (2011/65/EU) strengthening compliance requirements and extending its scope to cover all EEE unless explicitly exempted. RoHS 3 (2015/863) broadened the restricted substances list by including four phthalates.

Restricted substances

The RoHS Directive restricts the following substances:

Core substances

The original RoHS directive restricted six hazardous substances, including mercury, lead, hexavalent chromium, cadmium, and two types of flame retardants — PBB and PBDE.

Additional substances in RoHS 3

RoHS 3 expanded the list by adding four phthalates — DEHP, BBP, DBP, and DIBP. These are mainly used as plasticizers and have been restricted due to their harmful effects.

Maximum concentration values (MCV)

Each restricted substance has a maximum allowable concentration of 0.1% (1,000 ppm), except for cadmium, which has a stricter limit of 0.01% (100 ppm). These limits apply to any single material within a product, not just the overall product composition.

In-scope product categories

RoHS 2 expanded the scope of covered products, adding an 11th category to cover all EEE:

1. Small household appliances 

2. Large household appliances 

3. Consumer equipment, such as musical instruments

4. Lighting equipment

5. IT and telecommunications equipment

6. Electrical and electronic tools like drills and sewing machines

7. Toys, leisure, and sports equipment, such as game consoles and e-bikes

8. Medical devices 

9. Monitoring and control instruments e.g., smoke detectors

10. Automatic dispensers like vending machines and ATMs

11. All EEEs not included in the first 10 categories unless specifically exempt.

Compliance requirements

Importers, manufacturers, and distributors must ensure that their equipment complies with RoHS restrictions before placing it on the market. 

Testing and certification

EEE must undergo testing, such as X-ray fluorescence (XRF) screening and laboratory chemical analysis, to be allowed in any EU or EEA market. 

CE marking

The “CЄ” or “Conformite Europeenne” mark can be used to prove that the vendor has conducted the necessary tests to ensure RoH compliance. All EEE products must bear this marking to satisfy legal requirements.

Documentation and traceability

Companies must keep their technical documents associated with EEE up to date, including test reports, declarations of conformity (DoC), and supply chain records. These must be ready to show to regulators when needed to prove compliance and track the product throughout its lifecycle.

Eurasian conformity mark

If a company wants to sell a product in the Eurasian Economic Union (EAEU), which includes Kazakhstan, Russia, Belarus, Kyrgyzstan, and Armenia, the product must pass a conformity check. This means proving that it meets safety and technical rules either through an EAC certification or declaration. If the product passes, it gets a Eurasian Conformity (EAC) mark, similar to the CE mark in Europe.

Exemptions and exceptions

RoHS allows exemptions for specific instances where eliminating restricted substances would be impractical. 

A technical exemption is granted when it would technically be impossible to replace a restricted substance without risking product safety, such as in certain medical devices. 

A time-limited exemption encourages the development of alternative materials. It expires after a set period unless renewed. Some EEE is entirely exempt from RoHS, including industrial tools, military equipment, and large-scale fixed installations. These exemptions are reviewed periodically and may be revised or removed over time.

Implications for businesses

RoHS compliance showcases a company’s commitment to responsible, sustainable practices. Vendors must ensure supply chain transparency, material testing, and proper documentation. Non-compliance can result in fines, product recalls, and cancelled business permits. Companies operating in multiple regions must also navigate different RoHS-like regulations, such as China RoHS and EAEU restrictions.