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A solid understanding of the laws is essential when dealing with environmental regulations and how to comply with them. RoHS is one of the most significant environmental legislations, especially in Europe. Here we discuss some of the RoHS FAQ.

General Questions

RoHS stands for Restriction of Hazardous Substances. This European Union-originating directive restricts the use of certain hazardous substances in Electrical and Electronic Equipment (EEE). After July 1, 2006, all applicable products sold in the EU must comply with RoHS.

RoHS limits the concentrations of the following hazardous chemicals found in EEE products:

  1. Lead
  2. Cadmium
  3. Mercury
  4. Hexavalent chromium (Cr(VI))
  5. Polybrominated biphenyls (PBB)
  6. Polybrominated diphenyl ethers (PBDE)
  7. Bis(2-ethylhexyl) phthalate (DEHP)
  8. Butyl benzyl phthalate (BBP)
  9. Dibutyl phthalate (DBP)
  10. Diisobutyl phthalate (DIBP)


For all of the prohibited chemicals listed above, Maximum Concentration Value (MCV) is 0.1% or 1,000 ppm, with the exception of cadmium, which has a ten times lower threshold of 0.01% or 100 ppm. Notably, the concentrations of these restricted compounds are regulated at the homogenous materials that comprise each component.

International bodies have been creating RoHS standards to assist manufacturers, importers, and third parties in evaluating products regarding this legislation. There are various RoHS standards. With this RoHS FAQ, we are presenting the following two examples:

  • To help with technical documentation for assessing EEE products against RoHS, the International Electrotechnical Commission (IEC) released standard EN IEC 63000:2018. It replaced the previous EU standard of EN 50581:2012 as of November 2021. Consequently, producers must adhere to the requirements for technical documentation provided in this harmonized standard to claim compliance with RoHS. Manufacturers should refer to EN IEC 63000 in their declaration of conformity.
  • Additionally, the IEC 62321 series of standards provides information for laboratory activities to test product samples against restricted RoHS substances.

An internal statement made by a manufacturer providing the RoHS status is known as a RoHS Certificate of Conformity (CoC). Generally, a CoC may apply to the entire production, a particular series, or just one part number.

On the other hand, the RoHS Declaration of Conformity (DoC) is a legally mandated document. Custom agents, for instance, may ask for the DoC of any EEE product entering their jurisdiction. A RoHS DoC must contain specific information, including the product’s unique reference, name and address of the producer, date, signature, etc.

A solder is a metal alloy used to form a permanent binding between two metal components. The traditional solder utilized in the electronics industry was a tin-lead alloy contains high amounts of lead. To protect the environment and human health, RoHS solders, also known as lead-free solders, are replacing conventional tin-lead alloys. Tin-copper, tin-copper-silver, and zinc-tin are three common RoHS solders used nowadays.

RoHS non-compliance can be costly for a manufacturer or importer. Failure to comply with this regulation may result in severe fines and imprisonment. Importantly, the consequences differ from a member State to another. Besides penalties, the non-compliant product may be withdrawn or recalled from the market. As a result, this will hurt the brand’s reputation.

RoHS FAQ - Scope

The EU RoHS scope is a very broad one.

Currently, the following product categories fall under the scope of the directive:

  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.

Since the adoption of EU RoHS 1 (Directive 2002/95/EC) in 2002, the scope of the regulation and the obligations of the EEE product manufacturers and importers have changed. RoHS 2 (Directive 2011/65/EU) and RoHS 3 (Directive 2015/863/EU) reflect these modifications. The main difference between these three directives is that restricted substances under RoHS 1 and RoHS 2 are the first six chemicals listed above, whereas RoHS 3 also covers the four additional phthalates. Another distinction relates to the expansion of product categories covered under each directive. RoHS 2, also known as RoHS recast, broadened the scope included product categoriesIn addition, RoHS 2 clarified the lists of exemptions and exclusions (explained below). Notably, per RoHS recast, manufacturers and importers must prepare an EU declaration of conformity (DoC) and affix CE marking to the compliant finished products.

Due to technological considerations, some applications may benefit from RoHS exemptions regarding the restriction concentrations. Let this RoHS FAQ give you one example of exemption. For instance, copper alloys can contain up to 4% lead by weight under exemption 6c. Accordingly, Annex III of the directive lists current general RoHS exemptions, whereas Annex IV provides existing exemptions specific to Medical Devices and Monitoring and Control Instruments. As technology advances, some RoHS exemptions may become obsolete or modified. Therefore, manufacturers and importers should regularly check these listings.

On the other hand, RoHS provides a few product exclusions. Some products are out of the RoHS scope, including:

  • Large-scale electronic products
  • Military purposes products
  • Aerospace equipment (it is under AD-DSL regulation)
  • Active implantable medical devices
  • Research and development devices
  • Photovoltaic panels
  • Automotive products (it is under End-of-Life Vehicles (ELV) regulation)
  • Batteries (it is under the battery Directive)
  • Packaging (it is under the packaging Directive)

Large-scale electronic products are either Large-Scale Fixed Installations (LSFI) or Large-Scale Stationary Industry Tools (LSSIT). RoHS does not apply to these two product groups. Both groups include combinations of various EEE for permanent usage at a particular location installed and de-installed by professionals. Notably, LSFI and LSSIT may overlap. Furthermore, the producer, importer, or any other economic participant engaged is responsible for determining whether his tool or installation falls under either RoHS exclusion. Other regulations may apply, including Electromagnetic Compatibility (EMC), Low Voltage, and Machinery Directives.

The followings are examples of LSFIs:

  • Passenger lifts
  • Conveyor transport systems
  • Production and processing lines, comprising robots and machine tools
  • Electrical distribution systems (e.g., generators)
  • Automated storage systems
  • Cooling and heating systems permanently installed and only intended for non-residential use
  • Railway signaling infrastructure

This RoHS FAQ gives the following LSSITs  common examples:

  • Cranes
  • Machines used for industrial manufacturing and processing purposes, such as metal forming presses, newspaper printing presses, CNC lathes, and Bridge-type milling and drilling machines
  • Machines used for testing workpieces, including laser, deep ultraviolet defect detection systems, and automated integrated circuit board testers

There are discussion taking place to restrict the following seven hazardous substances under RoHS:

  1. Beryllium
  2. Cobalt (dichloride and sulphate)
  3. Diantimony trioxide
  4. Indium phosphide
  5. Medium Chain Chlorinated Paraffins (MCCPs)
  6. Nickel (sulphate and sulfamate)
  7. Tetrabromobisphenol A (TBBP-A)


MCCPs and TBBP-A are additional RoHS susbtances in the EU.

RoHS FAQ - Accros the Globe

As a rule of thumb, unless explicitely excluded, all EEE devices sold in any European country must adhere to RoHS. Since RoHS is a Directive, each EU member State implements RoHS in a different way. Thus, manufacturers and importers should be familiar with the EU directive and understand the unique ways each country executes it.

Many countries worldwide have adopted RoHS-like regulations, including China, the UK, United Arab Emirates, etc. One market may differ from another in terms of the scope, the listed hazardous chemicals, and the appropriate exemptions. Therefore, every EEE business considering international growth must be familiar with the laws of the target country regarding hazardous substances. Although there are presently no federal RoHS-like regulations in the US, some states (notably California) have such legislation.

Electrical and electronic equipment sold in China must comply with China RoHS. Similar to EU RoHS 2, China RoHS restricts the same six substances (i.e., lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers (PBDEs)). The thresholds for both RoHS regulations are the same.

However, except for the products below, the China RoHS thresholds trigger an obligation de declares chemicals:

  1. Air conditioners
  2. Refrigerators
  3. Washing machines
  4. Electrical water heaters
  5. Photocopiers
  6. Fax machines
  7. Printers
  8. Monitors
  9. Televisions
  10. Microcomputers
  11. Mobile communication devices
  12. Telephones


As a result, according to China RoHS, the product must bear an Environmental Friendly Use Period (EFUP) label and a RoHS table in Chinese listing the restricted hazardous substances that exceed the general thresholds. The product must have a green “e” EFUP label when non of the hazardous substances are present at the level of homogenous materials.

Finally, unlike EU RoHS, China RoHS applies to large-scale electronic products and batteries.

Contact Enviropass to learn more about RoHS and how to assess your products against it.