Overview#
RoHS keeps specific toxic substances out of electronics. It limits how much lead, mercury and similar materials a circuit board may contain, and the caps are very low.
Ten substances, capped at 0.1% by weight in each homogeneous material, except cadmium at 0.01%. You prove it with a CE mark, an EU Declaration of Conformity, and technical documentation (see EN IEC 63000).
What it restricts#
RoHS restricts ten substances in electrical and electronic equipment (EEE). The maximum concentration is 0.1% by weight in each homogeneous material. The one exception is cadmium, which is capped at 0.01%.
| # | Substance | Limit (by weight, per homogeneous material) |
|---|---|---|
| 1 | Lead (Pb) | 0.1% |
| 2 | Mercury (Hg) | 0.1% |
| 3 | Cadmium (Cd) | 0.01% |
| 4 | Hexavalent chromium (Cr VI) | 0.1% |
| 5 | Polybrominated biphenyls (PBB) | 0.1% |
| 6 | Polybrominated diphenyl ethers (PBDE) | 0.1% |
| 7-10 | Phthalates DEHP, BBP, DBP, DIBP | 0.1% each |
The four phthalates were added by Directive (EU) 2015/863, often called "RoHS 3". Annex II adds one carve-out: the restriction of DEHP, BBP and DBP does not apply to toys that are already restricted for those three phthalates by entry 51 of REACH Annex XVII.
Article 4(1) says the restriction covers the EEE "including cables and spare parts for its repair, its reuse, updating of its functionalities or upgrading of its capacity". A replacement cable or a service part is therefore in scope in its own right, subject to the transitional rules for older equipment below.
Try your own figures against the limits:
Use any unit (mg, g…) as long as both fields use the same one.
RoHS-Grenzwerte gelten je homogenem Werkstoff, der kleinsten Einheit, die sich mechanisch trennen lässt, nicht dem Gesamtbauteil. Cadmium hat 0,01 %, alle anderen 0,1 %. Ausnahmen (Anhang III/IV) können einzelne Verwendungen erlauben.
RoHS-Richtlinie 2011/65/EU, Anhang II ↗Why the limit is "per homogeneous material"#
The threshold does not apply to the whole product. It applies to each homogeneous material, which Article 3(20) defines as "one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes". That is why suppliers have to declare composition at a fine level of detail, for example through a Full Material Declaration.
Which products RoHS covers#
RoHS applies to electrical and electronic equipment in the eleven categories of Annex I. Since category 11 is "other EEE not covered by any of the categories above", the list is open scope: everything that meets the EEE definition is covered unless Article 2(4) takes it out.
Equipment necessary for the security of Member States, including arms, munitions and war material for specifically military purposes. Equipment designed to be sent into space. Equipment specifically designed to be installed as part of other excluded or out-of-scope equipment, which works only as part of it and can be replaced only by the same specifically designed equipment. Large-scale stationary industrial tools. Large-scale fixed installations. Means of transport for persons or goods, except electric two-wheel vehicles that are not type-approved. Non-road mobile machinery made available exclusively for professional use. Active implantable medical devices. Photovoltaic panels intended for a system designed, assembled and installed by professionals for permanent use at a defined location. Equipment specifically designed solely for research and development and made available only business-to-business. Pipe organs.
Being a niche product. Being sold only to businesses (only R&D equipment gets that relief). Being a cable or a spare part sold on its own for repair. Being a small machine that happens to sit in a factory: "large-scale" in the directive means machinery or installations that professionals permanently install and de-install, not anything industrial. Being a medical device or a monitoring instrument: those were phased in later, but they are in.
When each group came into scope#
Article 4(4) follows the same dates for cables and spare parts: parts for the repair, reuse, updating or upgrading of equipment placed on the market before its group's date are not caught, and the same applies to parts for equipment that benefited from an exemption while it was in force. Article 4(5) adds a narrow allowance for reused spare parts taken from old equipment, on condition that the reuse happens in "auditable closed-loop business-to-business return systems" and is notified to the consumer.
What "RoHS compliant" actually means#
There is no RoHS certificate and no approval body. RoHS is a CE marking directive: the manufacturer assesses the product, declares conformity and takes responsibility. Article 7 lists what that involves.
The CE mark on an electronic product does not tell you which directives it covers. RoHS shares the mark with the Low Voltage, EMC and Radio Equipment Directives among others, and the only place that says which ones were applied is the Declaration of Conformity. When a supplier says a product is "CE marked", ask for the declaration and read whether 2011/65/EU is on it.
How compliance is shown#
Proving RoHS compliance means building a paper trail from supplier data to the CE mark.
Exemptions#
Annex III (all EEE) and Annex IV (medical devices and monitoring and control instruments) list applications in which a restricted substance may still be used, for example lead in certain high-melting-temperature solders. Browse all 157 exemptions.
An exemption is granted or renewed under Article 5(1)(a) only where substitution is scientifically or technically impracticable, where the reliability of substitutes is not ensured, or where the total negative environmental, health and consumer safety impacts of substitution are likely to outweigh its benefits. Article 5(2) caps each exemption at up to five years for categories 1 to 7, 10 and 11, and up to seven years for categories 8 and 9, after which it has to be renewed or it lapses.
History#
A directive, so it lives in national law#
RoHS is a directive, not a regulation. Each member state transposes it, and the obligations you are enforced against are the national ones. In Germany that is the Elektro- und Elektronikgeräte-Stoff-Verordnung (ElektroStoffV). The substances, limits and exemptions are the same everywhere because the directive leaves no room on those points, but the market surveillance authority and the penalties are national.
How it relates to other topics#
- REACH is the broader EU chemicals regulation. RoHS targets a fixed list specifically in electronics, while REACH covers all substances.
- WEEE is the waste-side companion: RoHS decides what may go into equipment, WEEE what happens to it at end of life. The two use the same EEE definition but not the same exclusions.
- Data to prove RoHS compliance flows through formats like IPC-1752A and IEC 62474.