EU RoHS (Restriction of Hazardous Substances)

Restricts hazardous substances in electrical and electronic equipment sold in the EU.

Originally adopted in 2003 and recast as Directive 2011/65/EU (RoHS 2), the Restriction of Hazardous Substances Directive limits the use of specific hazardous materials in the manufacture of electrical and electronic equipment (EEE). The directive restricts six original substances -- lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE) -- and was later expanded to include four additional phthalates (DEHP, BBP, DBP, and DIBP) from 22 July 2019 for most categories. RoHS aims to protect human health and the environment by reducing exposure to these hazardous substances throughout the lifecycle of electronic products.

RoHS applies to manufacturers, importers, and distributors of electrical and electronic equipment falling within eleven defined categories, including large and small household appliances, IT and telecommunications equipment, consumer electronics, lighting, toys, medical devices, and monitoring and control instruments. The directive covers equipment with a voltage up to 1,000 V AC or 1,500 V DC, and applies regardless of whether the equipment is intended for consumer or professional use. Since the RoHS 2 recast, the scope has been open-ended, meaning new product categories can be included without legislative amendment.

Compliance requires manufacturers to ensure that restricted substances do not exceed the maximum concentration values set by the directive: 0.1% by weight in homogeneous materials for most substances, and 0.01% for cadmium. Manufacturers must prepare technical documentation and an EU declaration of conformity, and affix the CE marking to products before placing them on the market. Where exemptions exist -- for applications where no technically feasible alternative is available -- manufacturers must apply for and obtain time-limited exemptions, which are periodically reviewed and may be renewed, restricted, or revoked.

RoHS intersects with REACH, as both regulations address hazardous chemicals but from different angles: REACH applies broadly to chemical substances across all products and industrial uses, while RoHS specifically targets hazardous substances in electrical and electronic equipment. In practice, companies in the electronics sector must manage compliance with both frameworks simultaneously, ensuring that their products meet both the substance restrictions of RoHS and the registration and communication requirements of REACH. RoHS also connects to the CE Marking framework, as the CE mark on EEE signifies, among other things, compliance with RoHS requirements.

For businesses in the electronics and electrical equipment sector, RoHS compliance is a prerequisite for EU market access. Enforcement is carried out by national market surveillance authorities, which can withdraw non-compliant products, impose fines, and require corrective actions. As exemptions are reviewed and new substance restrictions may be introduced, ongoing monitoring and supply chain management are essential to maintaining compliance in this evolving regulatory landscape.

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