RoHS (Restriction of Hazardous Substances) is an EU directive that restricts ten hazardous substances in electrical and electronic equipment. Manufacturers, importers, and distributors supplying covered products to the EU market must meet its requirements. Non-compliance can prevent products from being sold and trigger corrective action, recalls, or penalties.
What Does RoHS Stand For?
RoHS stands for Restriction of Hazardous Substances. In electronics manufacturing, it means controlling restricted chemicals in the materials that make up a product, then keeping evidence that the production version complies.
The legal foundation is the EU RoHS Directive, 2011/65/EU, as amended. It covers substance restrictions, manufacturer responsibilities, technical documentation, and conformity requirements.
“RoHS compliant” describes a product’s compliance with applicable requirements. It does not mean a factory has a universal approval covering everything it makes.
A supplier might assemble compliant boards and still fit a non-compliant cable, connector, or enclosure. The purchasing decision therefore needs to reach beyond the PCB assembly line.
What Substances Does RoHS Restrict?
RoHS currently restricts ten substances or substance groups. The European Commission’s RoHS overview identifies the full list, including four phthalates added through the amendment commonly called RoHS 3.
| Substance | Max Concentration |
|---|---|
| Lead (Pb) | 0.1% / 1,000 ppm |
| Mercury (Hg) | 0.1% / 1,000 ppm |
| Cadmium (Cd) | 0.01% / 100 ppm |
| Hexavalent chromium (Cr VI) | 0.1% / 1,000 ppm |
| Polybrominated biphenyls (PBB) | 0.1% / 1,000 ppm |
| Polybrominated diphenyl ethers (PBDE) | 0.1% / 1,000 ppm |
| Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% / 1,000 ppm |
| Butyl benzyl phthalate (BBP) | 0.1% / 1,000 ppm |
| Dibutyl phthalate (DBP) | 0.1% / 1,000 ppm |
| Diisobutyl phthalate (DIBP) | 0.1% / 1,000 ppm |
These limits apply by weight in each homogeneous material, subject to applicable exemptions. A homogeneous material cannot be separated into different materials by mechanical actions such as cutting, grinding, or unscrewing.
Think of a cable’s plastic insulation, a solder joint, or a contact’s plating. You cannot average a failing material across the weight of the finished device.
For purchasing teams, that makes exact material and component identification essential. “Same connector, different plating” may require a fresh compliance review even when the drawing and electrical specifications stay the same.
Who Needs to Be RoHS Compliant?
Manufacturers, importers, and distributors have different obligations for covered equipment supplied to the EU market:
- Manufacturers must ensure conformity, prepare technical documentation and an EU Declaration of Conformity, and apply CE marking.
- Importers must verify that the manufacturer has fulfilled the relevant obligations before placing equipment on the market.
- Distributors must exercise due care and check required markings and documentation.
A company selling equipment under its own name or trademark can carry manufacturer responsibilities even when an overseas contractor builds it.
Products manufactured in Taiwan, China, Colombia, or the US face the same EU requirements when supplied to that market. Industrial or B2B equipment is not automatically excluded; check the actual product scope and any specific exclusion.
Non-compliance can become a logistics problem before the first customer receives a unit. Under the EU market surveillance framework, authorities can suspend customs release and refuse release for free circulation where the relevant conditions are met.
Other consequences include corrective action, withdrawal, recall, and national penalties. There is no single EU-wide RoHS fine.
The commercial bill can include storage, replacement parts, board rework, redesign, repeat validation, and missed deliveries. Discovering a problem before a purchase order is released is considerably cheaper than discovering it in finished inventory.
Is RoHS Only an EU Requirement?
RoHS originated in the EU, but other markets have their own hazardous-substance rules. An EU compliance package does not automatically satisfy every destination.
China RoHS has its own scope, marking, substance-disclosure, and conformity-assessment requirements. China’s 2026 catalogue guidance addresses ten restricted substances under its updated framework. Check the applicable implementation dates and whether the product falls within the compliance-management catalogue before specifying evidence.
UK RoHS also requires product compliance and supporting documentation. The UK government’s guidance explains differences between Great Britain and Northern Ireland, including their exemption systems. A familiar substance list does not remove the need to check local requirements.
Within the EU, REACH creates separate chemical obligations. The ECHA Candidate List identifies substances of very high concern that can trigger communication and other duties. It is not simply a longer RoHS prohibition list.
Ask suppliers to identify which regulations their declarations cover. A document labelled “environmental compliance” leaves too much room for interpretation.
How Do RoHS 1, RoHS 2, and RoHS 3 Differ?
These names describe the original directive, its recast, and a later substance-list amendment.
| Common name | Legal reference and timing | Main change |
|---|---|---|
| RoHS 1 | 2002/95/EC; restrictions applied from July 1, 2006 | Restricted the original six substances or groups |
| RoHS 2 | 2011/65/EU; recast applied from January 3, 2013, with scope changes phased in | Added the CE conformity framework and expanded coverage over time |
| RoHS 3 | (EU) 2015/863; additional restrictions generally applied from July 22, 2019 | Added DEHP, BBP, DBP, and DIBP; later application for medical and monitoring/control equipment |
The 2015/863 amendment changed Annex II of RoHS 2. “RoHS 3” is industry shorthand, rather than a replacement directive.
When reviewing supplier paperwork, check coverage of all ten substances and any claimed exemptions. A six-substance report alone leaves a gap.
How Can You Know If Your Manufacturer Is RoHS Compliant?
Ask for evidence tied to your product, its approved bill of materials (BOM), and its production revision. A logo on a quotation tells you very little.
1. Match declarations to actual part numbers. Request supplier declarations or material data for components, solder, cables, plastics, coatings, and other incorporated materials. Check manufacturer names, part numbers, revisions, and coverage of all ten substances.
2. Review the technical documentation. Ask how the supplier assesses missing or unreliable evidence. The European Commission identifies EN IEC 63000:2018 as the harmonised technical-documentation standard. Use it to structure the evidence review and determine where further investigation is needed.
3. Investigate exemptions. If a component relies on an exemption, record its reference, permitted application, relevant equipment category, and current validity. The Commission’s exemption guidance explains that exemptions apply under specific conditions. “Lead exempt” is insufficient detail for a release decision.
4. Check production and substitution controls. Confirm how the factory separates materials, traces batches, and approves alternate parts. Require compliance review before substitutions enter production. An approved prototype cannot prove the status of an undocumented replacement used six months later.
5. Agree on the release package. Identify who signs the EU Declaration of Conformity, who maintains the technical file, and how documents remain accessible. Manufacturers must retain the technical documentation and declaration for ten years after equipment is placed on the market.
RoHS generally uses manufacturer conformity assessment; it does not require a universal third-party “RoHS certificate.” UL certification addresses a separate certification context and cannot replace RoHS evidence.
Include document collection, testing where needed, and possible requalification in the NRE budget before approving mass production. Assign responsibility for updating evidence when the BOM changes.
For a project with Titoma, put the compliance deliverables and ownership into the manufacturing agreement before production release. That gives engineering, sourcing, and the manufacturing team a concrete acceptance checklist.
