Exploring RoHS Regulations Worldwide: A Country-by-Country Breakdown

What is RoHS? 

RoHS stands for Restriction of Hazardous Substances. It is a directive implemented by the European Union to regulate the use of specific hazardous materials found in electrical and electronic products. Established on July 1, 2006, the main goal of RoHS is to reduce the environmental and health risks associated with the disposal of electronic equipment by restricting the use of certain toxic substances. The original RoHS directive, also known as Directive 2002/95/EC, came into effect in 2006. It restricts the use of the following six hazardous materials:

1. Lead (Pb)

2. Mercury (Hg)

3. Cadmium (Cd)

4. Hexavalent chromium (Cr VI)

5. Polybrominated biphenyls (PBB)

6. Polybrominated diphenyl ethers (PBDE)

The directive was revised and updated in 2011, leading to the RoHS 2 directive (Directive 2011/65/EU), which added further regulations and expanded the scope of the original directive. RoHS 2 also introduced CE marking, indicating compliance with RoHS requirements. Another update, known as RoHS 2.1 or sometimes RoHS 3—and, officially, Directive 2015/863—came into effect on July 22, 2019, adding four more restricted substances:

7. Bis(2-ethylhexyl) phthalate (DEHP)

8. Butyl benzyl phthalate (BBP)

9. Dibutyl phthalate (DBP)

10. Diisobutyl phthalate (DIBP)

What Products Does RoHS Apply To?

RoHS applies to a wide range of electronic and electrical equipment, including household appliances, IT and telecommunications equipment, consumer electronics, lighting, power tools, and more. The RoHS reach encompasses all the billion-dollar industries you’d expect—computing, kitchen appliances, video games—and some that might not immediately jump to mind, including medical devices, e-cigarettes, and smart treadmills. Compliance with RoHS ensures that they are safe for use and environmentally friendly when disposed of. 

Not Limited To The EU: The Widespread Adoption of RoHS

Since its introduction in the EU, many countries outside Europe have adopted regulations similar to the EU's RoHS Directive. Their goal? To restrict the use of hazardous substances in electronic and electrical equipment in order to protect their environments, too. While these laws generally mirror the EU's approach, they often have small, subtle variations in scope, restricted substances, and enforcement mechanisms.

A List of RoHS Regulations Around the World

Here is a comprehensive list of countries with a version of the EU RoHS Directive (in alphabetical order): 

Australia

• Known As: Australian Hazardous Substances in Electrical and Electronic Equipment
• Description: Australia has guidelines that closely follow the EU RoHS Directive, although formal nationwide regulations are still under consideration.
• Scope: Applies to certain categories of electronic and electrical equipment.

Brazil

• Known As: ABNT NBR IEC 63000
• Description: Still in the draft stage, but it has a renewed interest under the current administration.
• Scope: Aligns to the initiatives in the original EU RoHS Directive.

China

• Known As: China RoHS (Administrative Measure on the Control of Pollution Caused by Electronic Information Products)
• Description: Contains labeling requirements for electronic information products (EIPs) that contain any of the six hazardous substances similar to EU RoHS Directive: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE.
• Scope: China RoHS initially just applied to electronic information products (EIP), but now it applies to most electrical and electronic products

Eurasian Economic Union (EAEU)

• Known As: Technical Regulation TR CU 037/2016
• Description: The EAEU member states of Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia have adopted a directive that aligns with the most recent EU RoHS Directive.
• Scope: The regulation mirrors the EU EEE categories.

Iceland

• Known As: RoHS
• Description: While not a member of the EU, Iceland has adopted the EU RoHS Directive as a member of the European Economic Area (EEA).
• Scope: Adheres directly to EU RoHS Directive requirements. 

India

• Known As: E-Waste Management Rules
• Description: Restricts lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE.
• Scope: Contains RoHS-like restrictions on hazardous substances in electronic and electrical equipment.

Japan

• Known As: J-MOSS (Japanese Industrial Standard for the Marking of Specific Chemical Substances)
• Description: J-MOSS focuses on the marking and identification of electronic products that contain specific hazardous substances.
• Scope: Primarily applies to home appliances and IT equipment.

Liechtenstein

• Known As: EU RoHS
• Description: Though it is not an EU member state, the country adheres to the EU RoHS Directive as a member of the European Economic Area (EEA).
• Scope: Directly adopts the EU RoHS Directive.

Norway

• Known As: Prohibition on Certain Hazardous Substances in Consumer Products (PoHS)
• Description: Restricts lead at a lower limit than the EU RoHS Directive, as well as additional substances of PCP, PFOA and MCCP.
• Scope: The regulation applies to more general consumer products instead of being specific to EEE equipment.

Singapore

• Known As: SG-RoHS
• Description: Restricts the same original six EU RoHS substances.
• Scope: The regulation delineates much narrower electronics categories, including communication devices and home appliances.

South Korea

• Known As: Korea RoHS (Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles)
• Description: Korea RoHS includes restrictions on lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE.
• Scope: Similar to the EU RoHS Directive, this law restricts the use of hazardous substances in electronic and electrical equipment.

Taiwan

• Known As: Restricted Chemical Substances in Electrical and Electronic Equipment
• Description: Mirrors the original EU ROHS Directive for the six restricted substances, with labeling requirements.
• Scope: Applies to similar categories as the EU RoHS Directive with voltage requirements.

Turkey

• Known As: Turkey RoHS
• Description: Aligns closely with the EU RoHS Directive, including restrictions on the same substances.
• Scope: Similar to the EU RoHS Directive, the regulation controls the use of hazardous substances in electrical and electronic equipment.

Ukraine

• Known As: Decree No. 139
• Description: The law is similar to the most recent EU RoHS Directive, which restricts 10 substances.
• Scope: The law adopts the EU’s 11 EEE categories and exemptions.

United Arab Emirates

• Known As: UAE RoHS
• Description: UAE RoHS requires declarations, technical files, and certifications for all 10 restricted substances.
• Scope: Aligns with the EU RoHS Directive for electric and electronic products.

United Kingdom

• Known As: UK RoHS
• Description: The UK adopted the EU RoHS Directive during its Brexit transition period.
• Scope: The only change the law makes to the EU RoHS Directive is in the product marking requirements, which it has changed from CE to UKCA.

United States (California)

• Known As: California RoHS
• Description: California's RoHS regulations, established under the Electronic Waste Recycling Act of 2003, restricts the use of lead, mercury, cadmium, and hexavalent chromium in certain electronic devices sold in the state.
• Scope: The law initially applied to video display devices, but there have been movements to align more closely with EU RoHS Directive to cover most electronics.

Vietnam

• Known As: Circular 30/2011/TT-BCT
• Description: Restricts of the original 6 EU RoHS Directive substances.
• Scope: Limited categories of electrical and electronic equipment (EEE).

Key Similarities

A key similarity between the various directives and regulations inspired by EU RoHS is that almost all of them restrict the same original six substances as the EU regulation (lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE).They also generally apply to a wide range of electronic and electrical equipment, including household appliances, IT equipment, consumer electronics, and lighting. Regardless of their specific differences, all of the various RoHS-style regulations are aimed at reducing the environmental and health risks associated with hazardous substances in electronic waste.

Key Differences

The main differences come down to the government or regulatory bodies in question, since each operates under a different set of constraints. Because of these restraints, the chief distinctions have to do with variations in how compliance is enforced, including testing requirements, certification processes, and penalties. It’s also possible for some countries to include additional substances or have different thresholds for restricted substances, based on studies unique to their geographical location. Each nation will also have differences in the timeline and phases of implementation, particularly among those with emerging economies.

Overall, while the specifics can vary, the global trend is towards harmonizing directives and regulations with the EU RoHS Directive to ensure safer and more environmentally friendly electronic products. While product safety is a key factor, implementing these regulations also helps countries to facilitate trade with the European Union, which is a major global market. The alignment of these rules helps alleviate the additional complexities and costs of having to meet multiple regulations for different markets while simultaneously leveling the playing field for global manufacturing. Finally, the EU is often ahead of the global curve when it comes to environmental policy. Mirroring the region's regulations can save other countries time and money by allowing them to utilize the EU's experience, research and frameworks to ensure a successful implementation and follow-through.