RoHS 2 Compliance: Electronics Restricted Substances Reference

RoHS 2 restricts the use of specific hazardous substances in electrical and electronic equipment (EEE) sold in the EU. Unlike CE marking — which is a declaration process — RoHS compliance means your product and its components must not exceed defined concentration limits for ten restricted substances. Most consumer electronics manufactured in China since 2006 are designed to be RoHS compliant, but compliance claims without supporting documentation are legally insufficient and commonly encountered.

Overview

EU Directive 2011/65/EU (RoHS 2) repealed the original RoHS Directive (2002/95/EC). It was amended by Directive 2015/863/EU to add four phthalates (DEHP, BBP, DBP, DIBP) as restricted substances from July 22, 2019. These four substances brought the total from six to ten.

RoHS applies to any manufacturer, importer, or distributor placing EEE on the EU market. Compliance is required for the finished product — not at import — but the manufacturer carries the obligation. Like CE marking, RoHS requires a Declaration of Conformity from the responsible person.

National enforcement varies: Germany’s Zollkriminalamt (customs enforcement), UK’s OPSS (post-Brexit), France’s DGCCRF. Products placed on RAPEX for RoHS violations are publicly named.

Applicability

RoHS 2 applies to all electrical and electronic equipment in 11 product categories:

Large household appliances
Small household appliances
IT and telecommunications equipment
Consumer equipment and photovoltaic panels
Lighting equipment (including LED bulbs)
Electrical and electronic tools
Toys, leisure, and sports equipment
Medical devices (from July 22, 2014)
Monitoring and control instruments (from July 22, 2014)
Automatic dispensers
Other EEE not covered by the above

Industrial fixed installations and large-scale fixed infrastructure are exempt. Spare parts for repair of EEE placed on the market before July 22, 2019 are exempt.

Key Requirements

Ten restricted substances and maximum concentration values (MCV):

Substance	Abbreviation	MCV (by weight of homogeneous material)
Lead	Pb	0.1% (1,000 mg/kg)
Mercury	Hg	0.1%
Cadmium	Cd	0.01% (100 mg/kg)
Hexavalent chromium	Cr6+	0.1%
Polybrominated biphenyls	PBB	0.1%
Polybrominated diphenyl ethers	PBDE	0.1%
Bis(2-ethylhexyl) phthalate	DEHP	0.1%
Benzyl butyl phthalate	BBP	0.1%
Dibutyl phthalate	DBP	0.1%
Diisobutyl phthalate	DIBP	0.1%

The 0.1% limit applies per homogeneous material — meaning a specific layer, coating, or material within a component that cannot be mechanically separated further. A PCB laminate, solder coating, and component housing are each assessed separately.

Exemptions are listed in Annex III (technical or scientific exemption, time-limited) and Annex IV (medical device exemptions). Key electronics exemptions:

Lead in high-melting-temperature solder (Pb >85%) — Annex III item 7a
Lead in server/storage/storage array systems — Annex III item 7c
Lead in glass of CRTs, fluorescent tubes — various items
Mercury in specific fluorescent lamps — various items

Exemptions have expiry dates and are periodically reviewed. Check the current status at the European Commission’s RoHS website before citing an exemption.

Process & Timeline

Step 1: Map your Bill of Materials (BOM) — list every component, material, and substance used in the finished product. PCB, housing, cables, solder, coatings, connectors. For PCB assembly products, pay particular attention to solder alloys and laminate materials.

Step 2: Collect supplier RoHS declarations — for each component and material. The declaration must:

Be dated (SVHC list and RoHS exemptions change — undated declarations are useless)
List all 10 restricted substances explicitly
State the maximum concentration for each substance
Include the manufacturer/supplier name and product identification

A generic “RoHS compliant” statement without substance-specific data does not satisfy legal documentation requirements. Use IPC-1752A Class C format (standardized materials declaration) or the equivalent JEDEC JEP706 format — these are industry-standard formats that cover all 10 RoHS substances explicitly.

Step 3: Verify high-risk components — certain components have historically caused RoHS failures:

Solder on PCBs (lead-free vs. leaded — verify Sn/Ag/Cu vs. Sn/Pb)
PVC cables and harnesses (may contain phthalates or Cd-based stabilizers)
Rubber and silicone gaskets (DEHP as plasticizer)
PCB laminates (flame retardants — PBB/PBDE in older formulations)
Metal plating on connectors (Cr6+ in hexavalent chromium plating)
Battery electrodes (Cd in NiCd, Pb in lead-acid)

Step 4: Third-party testing (optional but recommended for high-risk components):

XRF (X-ray fluorescence) screening: Non-destructive, fast, $50–200 per component. Detects Pb, Hg, Cd, Cr, Br (proxy for PBB/PBDE). Does not detect phthalates. Use for spot-checking solder and plating.
ICP-MS (Inductively Coupled Plasma Mass Spectrometry): Destructive, definitive. $500–1,500 per batch of 10–15 components. Required for cadmium and chromium verification in some cases.
GC-MS (Gas Chromatography Mass Spectrometry): Required for phthalates (DEHP, BBP, DBP, DIBP). $300–800 per sample.

Timeline: Collecting supplier declarations: 2–6 weeks (factories are often slow). Third-party testing: 1–3 weeks per batch.

Getting It Done from China

Most Tier-1 Chinese electronics manufacturers (Foxconn, BYD, Flextronics-tier suppliers) have robust RoHS documentation systems and can produce compliant declarations quickly. Smaller factories — especially component distributors and secondary suppliers — may provide generic declarations that do not meet legal requirements.

When onboarding a new supplier, include RoHS documentation requirements in your quality agreement. Specify: IPC-1752A Class C format, dated within 12 months, covering all 10 substances. Build documentation collection into your pre-production checklist so it does not delay shipment.

Chinese third-party labs for RoHS testing: SGS (multiple locations), Intertek, Bureau Veritas, CTI (Guangzhou). All offer XRF screening at Chinese locations and can do full ICP-MS/GC-MS testing.

Common Mistakes

Including RoHS documentation checks in your pre-production inspection checklist prevents costly delays at EU customs.

1. Accepting “RoHS compliant” labels without substance-specific data. Many Chinese factories stamp “RoHS compliant” on components and products without providing test data or formal declarations. This is not legally sufficient. If a market surveillance authority asks for your technical documentation, a stamp on a package does not help.

2. Not covering phthalates. The 2015 amendment adding four phthalates (effective July 2019) is frequently missed by factories with older documentation systems. Check that your supplier declarations explicitly cover DEHP, BBP, DBP, and DIBP — not just the original six substances.

3. Using exemptions without checking expiry dates. RoHS exemptions are time-limited and must be renewed by the European Commission. An exemption that was valid for your product category in 2022 may have expired. Always verify against the current Official Journal of the EU before production.

REACH SVHC Compliance — overlapping chemical obligations for EU market
CE Marking for Electronics — the declaration process that RoHS feeds into
Quality Inspection Services
Consumer Electronics Sourcing
PCB Manufacturing & SMT Sourcing
How to Source Electronics from China