RoHS Explained: The 10 Restricted Substances Every EU Exporter Must Know
If your product has a plug or a battery and you sell in the EU — phones, chargers, toys, lamps, power tools — RoHS sits on your compliance list next to CE and REACH. One of the three pillars for electronics entering the EU market.
What RoHS is: one sentence
Ten hazardous substances, banned above tight limits, in electrical and electronic equipment.
Full title: Directive 2011/65/EU (Restriction of the use of certain Hazardous Substances), published 2011, replacing the old RoHS 2002/95/EC. Note it's a Directive — member states transpose it into national law, unlike a Regulation which applies directly.
The 10 substances and their limits
| Substance | Limit (per homogeneous material) |
|---|---|
| Lead (Pb) | 0.1% |
| Mercury (Hg) | 0.1% |
| Hexavalent chromium (CrVI) | 0.1% |
| PBB | 0.1% |
| PBDE | 0.1% |
| DEHP, BBP, DBP, DIBP (4 phthalates) | 0.1% each |
| Cadmium (Cd) | 0.01% (the strictest) |
Two key points:
- Measured per homogeneous material — not the whole product; you break it down to single uniform materials (a screw, a plastic sleeve, a coating) and judge each. That's why you need material declarations from every supplier tier.
- The 4 phthalates came via the 2015 amendment (EU 2015/863), applying since July 2019. Soft plastics (cable jackets, soft-touch grips) are where most failures happen.
What it covers (and doesn't)
Covers: large/small household appliances, IT and telecom equipment, consumer electronics, lighting, power tools, toys/leisure/sports equipment, medical devices (partly), monitoring instruments, vending machines — essentially all common EEE.
Excluded (per the Directive text): military equipment, space equipment, large-scale fixed industrial tools, plus EEE outside the old 2002/95/EC scope had a transition until 22 July 2019. The exemption list is dynamic (lead in solders, ceramics — specific uses exempt, reviewed periodically). Industrial product makers should track exemption expiry dates.
Don't confuse it with REACH (the classic mix-up)
| RoHS | REACH | |
|---|---|---|
| Covers | 10 substances in EEE only | Chemicals in all products |
| How | Limits per homogeneous material | Registration / evaluation / authorisation / restriction (evolving SVHC list) |
| Who's responsible | Product manufacturer | Whole supply chain (importers too) |
Simple memory hook: RoHS is electronics' substance blacklist; REACH is the all-product chemicals management system. EU exporters need both.
The CE connection
RoHS isn't a standalone certification — it's part of CE compliance. The flow: test/assess hazardous substances per EN IEC 63000 → include in the CE Declaration of Conformity and technical file → affix the CE mark. There's no such thing as a separate "RoHS certificate" (lab RoHS reports are testing evidence, not certification).
China has its own RoHS
China's version is the "Management Measures for Restricted Use of Hazardous Substances in Electrical and Electronic Products" with GB/T 26572 (limits). Key difference: China RoHS is currently a labeling + disclosure regime (products must carry a hazardous substances table), not a direct ban — products in the compliance management catalog must meet the limits. Treat EU export and domestic China as two separate requirement sets.
Three practical tips for exporters
- Collect material declarations tier by tier — homogeneous-material judgment makes RoHS impossible without supply chain cooperation.
- Watch phthalates in soft plastics — the 4 substances added in 2019 are the top recall cause.
- Exemptions expire — products relying on exemption clauses (e.g., high-lead solder for specific uses) need to track expiry and redesign early.
The full RoHS Directive text (Article 4 limits, exemption clauses) is in the StdFlow knowledge base — sign up at stdflow.com and ask an AI agent for the original text, every answer cited.
FAQ
Which 10 substances does RoHS restrict?
Lead, mercury, hexavalent chromium, PBB, PBDE, plus 4 phthalates added by the 2015 amendment (DEHP, BBP, DBP, DIBP) — each at 0.1%; cadmium at 0.01%. Measured per homogeneous material.
How is RoHS different from REACH?
RoHS only covers 10 substances in electrical and electronic equipment (per homogeneous material); REACH governs chemicals in all products (registration, evaluation, authorisation, restriction with an evolving SVHC list). Exporters to the EU need both.
What's the relation between RoHS and CE marking?
RoHS is part of CE compliance — the DoC and technical file for electronic products must cover RoHS, supported by testing/assessment (e.g. EN IEC 63000). There is no standalone 'RoHS certificate'.
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