RoHS: Understanding the Directive & Compliance

What is the RoHS directive?

RoHS is a European Union directive relating to electronics and electronic device manufacturing. Specifically, the RoHS directive – Restriction of Hazardous Substances – limits the use of ten hazardous materials commonly found in electrical and electronic equipment and goods (EEE). It means that any relevant product that came to market after 1 July 2006 must pass RoHS compliance. The purpose of the directive is twofold: to reduce the pollution and prevent environmental damage caused by the restricted materials – such as during recycling or waste disposal – and to reduce the health risks associated with exposure to them.

RoHS applies to any business intending to directly sell, distribute or manufacture electronic and electrical products in the EU. Furthermore, it also applies indirectly, for example if a business sells such products to a third party who distributes in the EU. Since it is a directive, rather than a regulation, the RoHS is legally binding for all EU members but allows for some differences in implementation and enforcement.

Key details about the RoHS directive

Restricted by RoHS e.g. cadmium, mercury and lead

The restricted materials

In order to be RoHS compliant, products must contain no more than 0.1% of the following substances, except cadmium (no more than 0.01%):

Lead (Pb)
Mercury (Hg)
Cadmium (Cd)
Hexavalent chromium (CrVI)
Polybrominated biphenyls (PBB)
Polybrominated diphenyl ethers (PBDE)
Four types of phthalates (DEHP, BBP, DBP, DIBP) – effective as of 22 July 2019

RoHS compliance testing

Because of the far reach of the directive, and the development of globalisation, RoHS compliance testing is standard practice for the majority of electronics manufacturers and distributors across the world. Without putting electrical and electronic goods through testing, they are not compliant and therefore cannot be sold in the EU.

Affected product categories

Large household appliances
Small household appliances
IT and telecommunications equipment
Consumer equipment
Lighting equipment
Electrical and electronic tools
Toys, leisure and sports equipment
Medical devices
Monitoring and control instruments including industrial monitoring and control instruments
Automatic dispensers
Other EEE not covered by any of the above categories

Electrical and electronic product categories exempted from RoHS

Some product types are RoHS-exempt for a variety of reasons, such as some types of equipment used in large scale industry or in military applications. Lead is also exempt in some very specific applications. Note that the list of exemptions is liable to change. For example, medical devices were exempt in the original version of the RoHS directive, but the scope has since widened to include many types of medical devices.

silicon wafer in die attach machine in semiconductor manufacturing

The development of RoHS

As of 2019, there have been three versions of RoHS since the original was published in 2002 (Directive 2002/95/EC). RoHS 2 (Directive 2011/65/EU) widened the scope of the directive to include a broader range of EEE, including cables and spare parts, and also required additional compliance recordkeeping. RoHS 3 (Directive 2015/863) added the four phthalates to the list of restricted materials.

RoHS (Restriction of Hazardous Substances) marking on a box with electronic product

RoHS compliance: responsibility and enforcement

Compliance with the directive is concerned with EEE products that are placed on the EU market, not specifically with manufacturing. This means that an electric or electronic product that contains the restricted materials only violates the RoHS once it is distributed or sold in the EU. Therefore, responsibility to comply with RoHS also lies with the retailer and importer of the product, not just the manufacturer.

Manufacturers, distributors and importers of EEE products must adhere to certain documentation and labelling standards in order to show compliance. This includes labelling products within the scope of RoHS with the CE mark, which also indicates compliance with a range of other health and safety standards. In addition, they must provide a Declaration of Conformity per product, stating that it does not contain any of the restricted substances listed in the directive.

Failure to comply with the RoHS directive is penalised on a national basis by enforcement bodies, and the consequences can therefore differ considerably between EU member states. Typically, however, penalties for non-compliance involve a fine.