The EU RoHS Directive currently restricts 10 substances in electrical and electronic equipment, including 4 phthalates added through Directive (EU) 2015/863. Indeed, following the adoption of delegated Directive 2015/863 (sometimes also called RoHS 3), the European Union has amended Annex II of Directive 2011/65/EU (RoHS recast) and added 4 phthalates to the restricted substances list: DEHP, BBP, DBP, and DIBP.
The EU Directive restricts the use of certain hazardous substances in electrical and electronic equipment placed on the European Union market.
RoHS stands for Restriction of Hazardous Substances. It applies to many types of electrical and electronic equipment, unless a product is excluded or covered by a valid exemption.
The current EU RoHS restricted substances are:
Substance | Maximum Concentration in Homogeneous Material |
|---|---|
Lead, Pb | 0.1% |
Mercury, Hg | 0.1% |
Cadmium, Cd | 0.01% |
Hexavalent chromium, Cr(VI) | 0.1% |
Polybrominated biphenyls, PBB | 0.1% |
Polybrominated diphenyl ethers, PBDE | 0.1% |
| Substance | CAS # | Threshold (by weight in homogeneous materials) |
| Bis(2-ethylhexyl) phthalate (DEHP) | 117-81-7 | 0.1 % |
| Benzyl butyl phthalate (BBP) | 85-68-7 | 0.1 % |
| Dibutyl phthalate (DBP) | 84-74-2 | 0.1 % |
| Diisobutyl Phthalate (DIBP) | 84-69-5 | 0.1 % |
These limits apply at the homogeneous material level. This means that each individual material in a product must comply, not only the finished product as a whole.
According to the REACH regulation, these phthalates are also considered Substances of Very High Concern (SVHC).
The restrictions of these phthalates in homogeneous materials of Electrical and Electronic Equipment (EEE) apply starting July, 22nd 2019. Nevertheless, products categories 8 (medical devices) and 9 (monitoring and control instruments) are exempted until July 22nd, 2021.
Lead is one of the most common RoHS substances found in electrical and electronic equipment.
It may appear in solder, metal alloys, coatings, ceramics, glass, batteries, pigments, and electronic components. Some uses of lead may be allowed under specific RoHS exemptions, but these exemptions are limited and must be carefully verified.
Mercury may be found in certain lamps, switches, relays, sensors, and display technologies.
Mercury is restricted because of its toxicity and environmental persistence. If mercury is present, companies must verify whether a valid RoHS exemption applies.
Cadmium has a stricter RoHS limit than most other restricted substances: 0.01%.
It may appear in pigments, stabilizers, coatings, plating, batteries, contacts, and certain plastic materials. Cadmium is highly restricted because of its toxicity and environmental risks.
Hexavalent chromium may be used in certain surface treatments, anti-corrosion coatings, passivation layers, and metal finishes.
RoHS restricts hexavalent chromium, not all forms of chromium. For example, metallic chromium and trivalent chromium are different from hexavalent chromium.
PBBs are brominated flame retardants.
They were historically used in some plastics and polymers. Today, they are restricted under RoHS because of their persistence and potential health and environmental impacts.
PBDEs are another group of brominated flame retardants.
They may be found in plastics, cables, connectors, housings, and electronic components. Some PBDEs are also regulated under other chemical laws, including persistent organic pollutant rules.
Phthalates are typically used as plasticizers and may be found in rubber, adhesives, inks, coatings, cables, polymer foils, PVC compounds, etc. Phthalates are especially present in computers, electronic and electrical equipment, optical products, machinery and transport Equipment.
Note: HBCDD has originally been listed as a restricted phthalate which has eventually been withdrawn, since it is a REACH SVHC and a POP substance.
DEHP is a phthalate plasticizer.
It may be used in flexible plastics, especially PVC. In electrical and electronic equipment, it may appear in cables, wires, tubing, gaskets, labels, and soft plastic parts.
BBP is another phthalate restricted under EU RoHS.
It may be used as a plasticizer in flexible materials, coatings, adhesives, sealants, and certain polymer applications.
DBP is a phthalate that may be used in plastics, adhesives, inks, coatings, and sealants.
It is restricted under RoHS because of its hazardous properties and potential exposure risks in electrical and electronic products.
DIBP is similar to DBP and may be used as a plasticizer in polymers, adhesives, coatings, and flexible materials.
It is one of the four phthalates added to RoHS through Directive (EU) 2015/863.
Companies can demonstrate RoHS compliance through a combination of documentation and testing.
Useful evidence may include:
Testing is not always required for every part. A documentary review is often the first step. Targeted testing may be useful when supplier data is missing, outdated, incomplete, or unreliable.
RoHS compliance is essential for placing electrical and electronic equipment on the EU market.
Non-compliant products may face:
A proactive RoHS compliance program helps companies reduce risk before products reach the market.
The 10 EU RoHS restricted substances are lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP. The European Commission lists these substances as currently restricted under the RoHS Directive.
The RoHS limit for lead is 0.1% by weight in homogeneous material. Some lead applications may still be allowed if a valid RoHS exemption applies.
The RoHS limit for cadmium is 0.01% by weight in homogeneous material. Cadmium has a stricter limit than the other RoHS restricted substances.
A homogeneous material is a material that cannot be mechanically separated into different materials. For example, plastic insulation, solder, metal plating, glass, and coating layers may each be considered separate homogeneous materials.
Supplier documentation helps companies understand the materials, surface finishes, coatings, and potential nickel-containing parts in a product. Reviewing supplier data can help identify compliance risks before products are placed on the EU market.
No. RoHS applies to many types of electrical and electronic equipment, but some products may be excluded. Some applications may also benefit from specific exemptions. Companies should review the product category, scope, and exemption status before claiming compliance.
Yes. Enviropass can help companies identify applicable RoHS requirements, review supplier documents, assess material risks, verify exemptions, coordinate testing, and prepare RoHS technical documentation.
Please contact Enviropass for more information.
