RoHS Hub

Initially enacted in 2003, the Restriction of Hazardous Substances, or “RoHS,” took effect across all European Union member states beginning on July 1, 2006. In passing the directive, the EU sought to address the widespread use of potentially harmful chemicals and compounds in electrical and electronic equipment (EEE). As the European Commission explains on its website, “The rise in the production and use of electrical and electronic products, such as mobile phones, computers and kitchen appliances, has resulted in an increasing volume of electrical and electronic waste.” The various processes that go into the treatment and management of this EEE waste often release hazardous substances into the environment and atmosphere, leading to significant ecological and health problems. RoHS was implemented with the express goal of restricting the concentrations of these substances in electronics, thereby limiting their negative impacts.

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What Is RoHS?

Officially titled the Restriction of Hazardous Substances, RoHS is a directive enacted by the European Union (EU) to restrict the use of harmful and dangerous substances in electrical and electronic equipment (EEE). While RoHS technically entered into force in 2003, EU nations had until July 1, 2006 to fully comply with the regulation. From that point forward, RoHS restricted the use of six specific substances in EEE: Cadmium (Cd); Mercury (Hg); Lead (Pb); Hexavalent chromium (Cr6+); Polybrominated biphenyls (PBB); and Polybrominated diphenyl ethers (PBDE).

Since the directive was first adopted over two decades ago, the EU has expanded the scope of RoHS on several occasions. In 2011, Directive 2011/65/EU—often referred to as “RoHS 2”— increased the number of products within the remit of the regulation, while also introducing new obligations on EEE manufacturers. In 2015, Directive 2015/863, or “RoHS 3,” was passed, restricting four additional substances in EEE manufacturing: Bis(2-ethylhexyl) phthalate (DEHP); Butyl benzyl phthalate (BBP); Dibutyl phthalate (DBP); and Diisobutyl phthalate (DIBP).

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What Products Are Impacted by RoHS?

Though RoHS is broadly focused on electrical and electronic equipment, in order to be an effective regulation it relies on a precise, sharply delineated scope regarding covered products. To that end, the directive has established 11 product categories that are impacted by RoHS. While these categories all encompass products that utilize electronic components like transistors, diodes, and semiconductors to manipulate the flow of an electric current—thereby fulfilling the most fundamental definition of “electronics”—they also stretch across a slew of different industries and manufacturing fields.

Large household appliances
Small household appliances
Computing and communications equipment
Consumer electronics
Lighting equipment
Power tools
Toys and leisure and sports equipment
Medical devices and equipment
Monitoring and control devices
Automatic dispensers
All other electronic and electrical equipment not covered under the other categories.

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What Products Are Exempt From RoHS?

Certain categories are exempt from the restrictions imposed by RoHS. While the specific reasoning may vary from one product to the next, these goods are generally excluded because of their vital importance to critical concerns like national defense, scientific research and development, and human health. In some cases, the near-term costs associated with reformulating these products to adhere to RoHS may outweigh the long-term benefits.

Military equipment used for defense or national security.
Satellites, telescopes, and spacecraft.
Vehicles used for transport (with the exception of two-wheeled vehicles like electric motorcycles, electric dirt bikes, and electric bicycles).
Equipment used for professional research and development.
Non-road mobile machinery (NRMM), including construction and agricultural machinery.
Large-scale fixed installations (LSFI).
Large-scale stationary industrial tools (LSSIT).
Fixed-location photovoltaic panel (PV) installations.
Active Implantable Medical Devices (AIMDs).
Sub-equipment for out-of-scope equipment.
Battery cells (not including wiring).
Compact fluorescent light bulbs and lamps.
Spare parts for equipment that entered the market before RoHS took effect.

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What Is a RoHS Certification?

Manufacturers, importers, and other suppliers of EEE in the European Union may choose to use an independent third party to ensure that they are fully compliant with RoHS. These organizations, which are also known as conformity assessment bodies (CABs), carry out a number of steps to obtain all the information necessary to comprehensively evaluate the compliance of their clients.

To issue a RoHS certification, a conformity assessment body needs to conduct chemical testing on the products in question in order to determine whether restricted substances are present above the EU’s legal thresholds. In addition, these organizations will typically investigate manufacturing processes, generally on-site; review all applicable documentation, including bills of materials (BOMs) and full material declarations (FMDs); and evaluate a technical file that encompasses product design structure, risk assessments, and manufacturing records.

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RoHS-Inspired Regulations Worldwide

Since RoHS was initially introduced in 2006, the EU environmental directive has served as something of a trailblazer for other laws regulating EEE around the globe. Many of the largest nations and economies in the world now have regulations in place that draw from the RoHS framework in an effort to mitigate the negative impact of the hazardous substances used in electronics. Examples of these regulations include China RoHS, UK RoHS, India’s E-Waste Management Rules, and Japan’s J-MOSS (Japanese Industrial Standard for the Marking of Specific Chemical Substances).

While the United States does not have a RoHS equivalent at the federal level, a number of states have adopted and implemented regulations limiting concentrations of specific heavy metals and other substances in electronics.

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A Closer Look at China RoHS

While dozens of countries around the world adhere to the original EU RoHS or a similar chemical regulation, the size and influence of China on worldwide electronics manufacturing make its version of the directive uniquely important. The country’s RoHS equivalent is officially known as the Administrative Measure on the Control of Pollution Caused by Electronic Information Products, and the regulation is published and maintained by the Ministry of Industry and Information Technology (MIIT).

Since the regulation’s inception in 2006, China RoHS has focused on the same six substances originally restricted by the EU’s RoHS: Lead (Pb); Mercury (Hg); Cadmium (Cd); Hexavalent chromium (Cr6+); Polybrominated biphenyls (PBB); and Polybrominated diphenyl ethers (PBDE). In June 2024, MIIT passed an amendment that added the four chemicals the original RoHS began regulating in 2015 to its own list of restricted substances. These include bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP). Once these restrictions go into effect beginning on January 1, 2026, China RoHS will be in full alignment with its EU counterpart.

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Understanding the Difference Between RoHS and REACH

RoHS and the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) are both environmental regulations administered and enforced by the European Union. Conflating the two, using them interchangeably, or assuming significant overlap between the laws, however, is a major misstep, because they differ significantly in both structure and scope.

While RoHS is exclusively focused on restricting the use of 10 hazardous substances across a number of different EEE categories, REACH is a more complex regulation. The chemical directive requires manufacturers and other in-scope businesses that fall within the purview of REACH to register chemical substances with the European Chemicals Agency by submitting comprehensive dossiers. In addition, REACH maintains a list of substances considered to be of “very high concern” (known as the Candidate or SVHC List), and presides over an authorization process for organizations seeking to use specific banned substances.

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Recent Proposed Additions to RoHS

In 2022, the European Commission submitted a proposal to add two new substances to the EU RoHS Annex II, which covers hazardous substances restricted by the directive: tetrabromobisphenol A (TBBPA), a flame retardant used in plastics and synthetic resins and found to be an endocrine system disruptor; and medium-chain chlorinated paraffins (MCCPs), a family of industrial chemicals believed to be persistent, bioaccumulative, and toxic (PBT).

While the European Commission proposal—which would have expanded the list of substances restricted by RoHS to 12—was originally expected to be adopted by 2024, it remains on hold with no definitive timetable for passing or entering into force.