If you’ve ever received a supplier declaration labeled “RoHS 3” and wondered whether it’s “newer” (or more valid) than RoHS 2, you’re not alone.
Here’s the key point:
EU RoHS is based on Directive 2011/65/EU (often called RoHS 2 or the “recast”).
What many people call “RoHS 3” usually refers to the 2015/863 amendment that updated Annex II by adding four phthalates.
So, in practice, “RoHS 3” is not a separate, standalone directive—it’s commonly shorthand for an important update within the RoHS 2 framework.
RoHS 1: 2002/95/EC (legacy directive, replaced)
RoHS 2: 2011/65/EU (the main directive you comply with today)
“RoHS 3”: common industry nickname for Directive (EU) 2015/863, which amended RoHS 2 by expanding the restricted substances list
For supplier declarations: you don’t need a document literally titled “RoHS 3” as long as it clearly demonstrates compliance with the current restricted substances list under 2011/65/EU (as amended).
EU RoHS compliance is anchored in Directive 2011/65/EU. Over time, that directive has been updated through multiple amendments. The amendment most people remember is 2015/863, because it expanded the restricted substances list—so people started saying “RoHS 3.” But legally speaking, you’re still operating under the RoHS 2 framework (2011/65/EU), just with amendments applied.
EU RoHS compliance is anchored in Directive 2011/65/EU. Over time, that directive has been updated through multiple amendments. The amendment most people remember is 2015/863, because it expanded the restricted substances list—so people started saying “RoHS 3.” But legally speaking, you’re still operating under the RoHS 2 framework (2011/65/EU), just with amendments applied.
Because 2015/863 was a big change that suppliers could easily “label.” It’s widely referenced since it added four phthalates to the restrictions list in Annex II.
So, you’ll often see:
“RoHS 2” meaning the original 6-substance scope, and
“RoHS 3” meaning the updated 10-substance scope.
That’s convenient language—but it can also create confusion, especially when a customer insists on “RoHS 3 certificates” without specifying what they actually need.
The original restriction framework came from the first RoHS directive (commonly referred to as RoHS 1), which was later replaced.
Directive 2011/65/EU is the current legal backbone of EU RoHS compliance and is often called RoHS 2 (recast).
Commission Delegated Directive (EU) 2015/863 updated RoHS 2 by amending Annex II (restricted substances list).
Under RoHS 2 (as amended), the commonly referenced Annex II list includes 10 restricted substances. The limits apply at the homogeneous material level (i.e., the smallest material you can mechanically separate).
EU RoHS targets electrical and electronic equipment (EEE) placed on the EU market, and the European Commission summarizes the directive’s purpose as reducing risks to health and the environment by restricting certain hazardous substances in EEE.
If you want a simple practical rule:
If your product needs CE marking and is EEE (with some exclusions), it’s very likely you need to consider RoHS.
Label Used in Industry | What it Usually Refers to | Key Practical Difference |
|---|---|---|
RoHS 1 | 2002/95/EC (legacy framework) | Earlier scope; replaced by recast directive |
RoHS 2 | 2011/65/EU (recast) | The core EU RoHS directive |
“RoHS 3” | 2015/863 amending RoHS 2 | Adds 4 phthalates to Annex II (10 total substances) |
Not necessarily.
What you actually want is a declaration that confirms compliance with:
Directive 2011/65/EU, and
its relevant amendments (including 2015/863 where applicable).
A supplier document titled “RoHS 2” can still be acceptable if it clearly covers the current restricted substances list and is written in a way that aligns with EU RoHS compliance expectations.
Supplier must confirm compliance with EU RoHS Directive 2011/65/EU, as amended (including Directive (EU) 2015/863), at the homogeneous material level, and provide supporting technical documentation upon request.
RoHS is shorthand for: Restriction of Hazardous Substances in electrical and electronic equipment—i.e., limiting certain substances used in EEE to reduce environmental and health risks.
It’s commonly used to refer to the 2015/863 amendment, but legally it’s an amendment to RoHS 2 (2011/65/EU), not a separate replacement directive.
It depends on what their declaration actually covers. If it still references only 6 substances, it may be incomplete for many modern customer requirements. Your best approach is to require compliance with 2011/65/EU as amended and ensure the declaration is substance-complete.
They were introduced by Commission Delegated Directive (EU) 2015/863, which amended Annex II of 2011/65/EU.
If you’re unsure whether a certificate is sufficient (or you want to audit the supply chain and back up compliance with solid documentation), we can help you verify RoHS status—especially when suppliers use inconsistent “RoHS 2 / RoHS 3” wording.
Questions on EU RoHS, or other RoHS regulations worldwide, like China RoHS? Contact Enviropass!
