Enviropass Logo

RoHS 1 VS RoHS 2 VS RoHS 3

Electrical and electronic equipment consists of hazardous substances such as heavy metals, flame retardants, and plasticizers. These harmful chemicals can cause severe environmental and public health issues. Consequently, since 2002, European Union has restricted the use of certain hazardous substances under various directives, including RoHS 2.

What is Europe RoHS?

The EU RoHS, which stands for Restriction of Hazardous Substances, applies to Electrical and Electronic Equipment (EEE) sold in the European market. RoHS is the primary requirement for environmental compliance of electrical and electronic devices. In particular, this regulation aims to decrease the negative impacts of EEE products on the environment and human health.


The ten restricted substances and their permitted threshold under EU RoHS are:

  1. Lead < 0.1% or 1000 ppm (parts per million)
  2. Cadmium <0.01% or 100 ppm
  3. Mercury < 0.1% or 1000 ppm
  4. Hexavalent chromium (Cr(VI)) < 0.1% or 1000 ppm
  5. Polybrominated biphenyls (PBB) < 0.1% or 1000 ppm
  6. Polybrominated diphenyl ethers (PBDE) <0 .1% or 1000 ppm
  7. Bis(2-ethylhexyl) phthalate (DEHP) < 0.1% or 1000 ppm (added in 2015)
  8. Butyl benzyl phthalate (BBP) < 0.1% or 1000 ppm (added in 2015)
  9. Dibutyl phthalate (DBP) < 0.1% or 1000 ppm (added in 2015)
  10. Diisobutyl phthalate (DIBP) < 0.1% or 1000 ppm (added in 2015)


Importantly, these permissible thresholds are at the level of the homogeneous materials that constitute each component in the product. In other words, this implies that the restrictions apply to any single material and not to the weight of the finished product.

Product Categories Covered by EU RoHS 2

According to the Annex I of the regulation, RoHS applies to products in the following categories:

EU RoHS product categories
  1. Large household appliances.
  2. Small household appliances.
  3. IT and telecommunications equipment.
  4. Consumer equipment.
  5. Lighting equipment.
  6. Electrical and electronic tools.
  7. Toys, leisure, and sports equipment.
  8. Medical devices.
  9. Monitoring and control instruments including industrial monitoring and control instruments.
  10. Automatic dispensers.
  11. Other EEE not covered by any of the categories above.

The Evolution of EU RoHS

RoHS’s scope and the obligations of EEE product importers have changed since the regulation’s implementation in 2002. Accordingly, the RoHS amendments, namely RoHS 2 and RoHS 3, reflect these changes. Here we discuss the differences between RoHS 1, RoHS 2 (RoHS recast), and the so-called RoHS 3 which in reality reflect a major amendment of RoHS 2.

The table below summarizes the main differences between RoHS 1, RoHS 2, and RoHS 3.


Effective Date

Restricted Substances

Product Categories Covered

Directive 2002/95/EC (RoHS 1)

July 1st 2006

Lead; Cadmium; Mercury; Hexavalent chromium; Polybrominated biphenyls (PBB); Polybrominated diphenyl ethers (PBDE)

Categories 1, 2, 3, 4, 5, 6, 7, and 10

Directive 2011/65/EU (RoHS 2) before the 2015/863/EU amendment

January 2nd 2013


Categories 1, 2, 3, 4, 5, 6, 7, 8, 9, and 10

Directive 2011/65/EU and the 2015/863/EU amendment (RoHS 3)

July 22nd 2019

Same + Bis(2-ethylhexyl) phthalate (DEHP); Butyl benzyl phthalate (BBP); Dibutyl phthalate (DBP); Diisobutyl phthalate (DIBP)


RoHS 1

Electronic Products RoHS 2

The European Union published Directive 2002/95/EC, known as RoHS 1, in 2002. The goal of RoHS 1 was to restrict the use of the first six hazardous chemicals indicated above in the production of various EEE products. This regulation is closely related to Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE) which establishes collection, recycling, and recovery objectives for EEE devices to address the issues related to the toxic waste in these products. On July 1, 2006, RoHS 1 directive became law in each Member State. As of this date, all relevant products sold in the EU market have to comply with RoHS. Besides, this directive applies to products falling under categories 1, 2, 3, 4, 5, 6, 7, and 10 mentioned above.

RoHS 2

In July 2011, Directive 2011/65/EU, also known as RoHS 2 or recast of RoHS 1, superseded the original RoHS regulation. Like RoHS 1, RoHS 2 limits the use of six hazardous substances in electrical and electronic devices. The followings are similarities and differences between RoHS 1 and RoHS 2:

  1. The RoHS 2 broadened the scope of products covered by RoHS 1. For instance, it added medical devices (category 8) and monitoring and control instruments (category 9) to its list of products. Moreover, it established separate compliance deadlines for each group.
  2. RoHS 2 offered a few exceptions to its regulations. Out of RoHS scope products include: some large-scale electronic products (i.e., large-scale fixed installations (LSFI) and large-scale stationary industrial tools (LSSIT)), military or aerospace equipment, active implantable medical devices, some research and development devices, and some photovoltaic panels. Furthermore, RoHS does not apply to batteries and packaging materials since they must adhere to other regulations.
  3. RoHS 2 directive also imposed additional obligations on EEE producers and importers. Subsequently, manufacturers and importers of products falling under a RoHS category must perform a conformity assessment, prepare an EU declaration of conformity (DoC), and affix CE marking to all compliant finished products.
  4. In addition, RoHS 2 provided two lists of applications that benefit from exemptions on its Annex III for general exemptions and Annex IV specific to medical devices and monitoring and control instruments. Manufacturers and importers should constantly monitor these lists since some RoHS exemptions are time limited.
Medical Devices RoHS 2

RoHS 3

In 2015, European Union amended RoHS 2 to include four additional chemicals to the initial list of six. These restricted substances include the four phthalates listed below:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)
RoHS 3 vaporizers

Directive 2015/863/EU, also known as RoHS 3, became effective on July 22, 2019. Moreover, RoHS 3 added category 11 for EEE products not covered by other categories. Examples of products in this category are electronic nicotine delivery systems (ENDS) such as e-cigarettes, cannabis vaporizers and vape pens, and two-wheeled electric vehicles.

Surprisingly, the requirement for DEHP, BBP, and DBP does not apply to toys since they are already subject to the restriction of these three phthalates under entry 51 of Annex XVII to European regulation 1907/2006/EC (EU REACH).

RoHS 2 Non-Compliance Consequences

Article 23 of the RoHS directive 2011/65/EU requires EU Member States to establish penalties for infringements of national provisions enacted per this regulation. Accordingly,  Member States must take all necessary steps to ensure the implementation of these obligations. Failure to comply with RoHS may result in severe penalties and legal consequences. For instance, you might face fines of up to 30,000 euros and up to one year in prison for importing a non-RoHS-compliant product into Germany.

Apart from the penalties, there is more to concern. Cases of RoHS non-compliance are typically publicized. This situation might lead to the withdrawal or recall of a product from the EU market and eventually hurt the brand’s reputation. Therefore, manufacturers and importers must ensure that their products comply with all the requirements of RoHS as this directive continues to evolve. Although adhering to RoHS requirements might be challenging, consumers and the environment will ultimately benefit from the restriction of these hazardous substances.

RoHS in Other Countries

China RoHS

In January 2016, the Chinese Ministry of Industrial and Information Technology (MIIT) issued the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, also known as China RoHS 2. The regulation became effective on July 1, 2016, and superseded its previous version. The original China RoHS, introduced in 2006, solely affected electronic information products (EIP). China RoHS 2 broadened the scope and impacted electrical and electronic products (EEE), similar to EU RoHS.

China RoHS restricts the same substances as EU RoHS, with the same thresholds at the homogenous material level. Notably, the inclusion of four phthalates was introduced in the 2022 amendment.

Like the EU CE marking, EEE products put into China’s Market must bear a label (Environmental Friendly Use Period (EFUP) label) indicating conformity with China RoHS regulations. Along with the EFUP label, the product tag should also contain a RoHS table in Chinese. Surprisingly, EEE products containing banned substances above the thresholds can still be marketed in China if labeled accordingly. Moreover, in contrast to EU RoHS, there are currently no exemptions available for China RoHS.


Despite the absence of a federal RoHS regulation in the US, several states have imposed restrictions comparable to EU RoHS. The US states with RoHS regulations in place are:

E-Waste USA
  • California
  • Illinois
  • Indiana
  • Minnesota
  • New Jersey
  • New York
  • Rhode Island
  • Wisconsin

The only state restricting all 10 EU RoHS substances is Wisconsin. Other jurisdictions limit a subset of the EU RoHS substances, such as heavy metals. For example, the chemicals restricted under California RoHS law are just the heavy metals – lead, mercury, cadmium, and hexavalent chromium.

Additionally, products covered under each US state law are fewer than those covered by EU RoHS. For instance, the only product covered under Indiana’s RoHS is household video display devices. Furthermore, the registration and reporting obligations differ in each jurisdiction.

RoHS-like Initiatives

Besides EU, USA, and China, there are other countries worldwide with RoHS initiatives, including:

RoHS Worldwide
  • Brazil
  • India
  • Japan (J-MOSS)
  • Norway
  • Singapore
  • South Korea
  • Taiwan
  • Turkey
  • United Arab Emirates

Do you need to assess electronic devices against RoHS? Ask for a free Enviropass consultation!