RoHS requirements apply in a growing number of markets, but product scope, restricted substances, conformity-assessment procedures, documentation and labelling obligations vary by jurisdiction. Achieving RoHS-compliant products worldwide therefore requires a market-by-market assessment.
Enviropass provides testing and technical support to help companies achieve product environmental compliance worldwide.
Key RoHS requirements may include:
RoHS regulations generally apply to electrical and electronic equipment (EEE), although the covered product categories vary by jurisdiction. The EU framework has a particularly broad scope, covering most household and professional equipment, medical devices, tools, monitoring and control instruments, and certain industrial products.
Aerospace, military and automotive products are generally outside the scope of RoHS. Batteries and packaging are also governed by separate requirements. However, other environmental regulations may apply to automotive equipment, batteries and packaging.
Many RoHS regimes are modelled on the European framework, including requirements adopted in the Eurasian Economic Union, the United Arab Emirates and Turkey. Nevertheless, conformity-assessment procedures can vary between jurisdictions.
Other jurisdictions, including China and Taiwan, have distinct substance, labelling and declaration requirements.
For technical reasons, certain materials or applications require restricted substances above the normal limits. For example, this is the case of lead in some copper alloys. As a result, enforcement authorities enable RoHS exemptions. They may be general to any electrical and electronic equipment or specific to certain product categories, like medical devices or monitoring and control instruments. Importantly, enforcement authorities periodically review exemptions and either replace, modify, or withdraw them, depending on technological progress. Enviropass maintains the updated EU RoHS exemptions.
The timing and nature of RoHS amendments vary by jurisdiction. In the EU, the framework has been amended repeatedly since its adoption. One significant amendment, Directive (EU) 2015/863, added four phthalates—DEHP, BBP, DBP and DIBP—to the list of restricted substances.
RoHS appeared in 32.5% of the Enviropass projects analyzed in 2026, making it the most frequently assessed regulatory requirement in our dataset.
In our assessments, lead was the RoHS substance most frequently encountered as a potential compliance risk, particularly in solder, metal alloys, and hardware.
This reinforces the importance of evaluating RoHS compliance at the homogeneous-material level and verifying whether applicable exemptions are properly documented, rather than relying solely on a general supplier declaration.
No. RoHS compliance covers more than lead. Although lead and its compounds are common concerns in electronics, RoHS regulations may also restrict other heavy metals, brominated flame retardants and phthalates.
Every regulation aims at restricting the use of hazardous substances contained in electrical and electronic equipment, to better protect the environment and human health. As a result, the waste of electrical and electronic equipment (WEEE) becomes easier to recycle and less harmful.
Electrical and electronic equipment may contain substances that can harm human health and the environment. At the end of a product’s useful life, these substances can complicate safe recycling and increase waste-treatment costs. Addressing hazardous substances during the design and sourcing stages can reduce these risks and facilitate responsible end-of-life management.
Typically, they are heavy metals (lead, mercury, cadmium, chromium hexavalent) and, depending on the jurisdictions, some additives in plastics, like PBBs, PBDEs, and phthalates (BBP, DBP, DEHP, and DIBP).
Countries and states like Australia, Canada, Japan, or the USA (other than a few States) don’t have RoHS laws as such, or regulations specifically dedicated to substances restrictions in electrical and electronic equipment.
However, this doesn’t mean that no applicable regulations apply at all. Legal obligations on hazardous substances are usually implemented, restricting mercury, lead, cadmium, and others. The objective is to reduce their use and the risk of exposure when importing, producing, or placing on the market mixtures, products, and devices.
Obligations to declare such substances to national agencies, and to obtain certificates of authorization are usually mandatory above certain thresholds.
No. RoHS and REACH differ in scope and in the substances they regulate. Both may apply to the same product within the same jurisdiction. RoHS primarily applies to electrical and electronic equipment, whereas REACH applies more broadly to substances, mixtures and articles.
RoHS compliance requires evidence that restricted substances do not exceed the applicable concentration limits at the homogeneous-material level, subject to any valid exemptions. Compliance may be demonstrated through analytical testing, documentary assessment or a combination of both. For complex products, the documentary approach should follow IEC 63000.
Enviropass combines documentary assessment with targeted analytical testing to provide a practical RoHS compliance strategy for complex products.
Jurisdiction | Scope of Electrical & Electronic Equipment (EEE) | Major Deviations from the EU |
|---|---|---|
European Union (EU RoHS / Directive 2011/65/EU, 2015/863 + other amendments) | 11 categories of EEE, including medical devices, monitoring & control instruments, cables, and spare parts | Reference standard globally; uses CE-marking and technical file; strict homogeneous material limits |
United Kingdom (UK RoHS) | Similar to the EU scope | Businesses may use either CE or UKCA marking for RoHS-regulated equipment placed on the market in Great Britain. CE marking is required in Northern Ireland, where UKCA alone is not recognized. |
China RoHS | All EEE listed in the “Catalogue for the Administration of the Restriction of Hazardous Substances in EEE” | China RoHS labelling and information-disclosure requirements apply broadly to electrical and electronic products. Products included in the applicable conformity-assessment catalogue must also meet substance restrictions and conformity-assessment requirements according to the relevant implementation dates. |
United States – State-Level RoHS (e.g., California, New Jersey, New York) | Typically TVs, displays, some large appliances | No federal law; state regulations vary; often narrower scope (primarily video displays) |
Japan (J-MOSS / JIS C 0950) | Seven product categories: PCs, televisions, refrigerators, air conditioners, etc. | J-MOSS is specifically a substance-information and labelling framework rather than a direct equivalent of EU RoHS. |
India RoHS (E-waste Management Rules) | All EEE listed in Schedule I | Restrictions align with the EU, but focus more on end-of-life handling & producer responsibility |
United Arab Emirates (UAE RoHS) | Broad EEE scope covering most imported electronics | Based on the EU regulation, but enforced through conformity assessments (ECAS/CoPC) and test reports |
Saudi Arabia (SASO RoHS) | Covered EEE aligned with the EU. The four phthalates restricted under EU RoHS are not covered. | Applicable exemption codes differ from those used by the EU. |
Turkey (TR RoHS) | Most EEE categories similar to EU | Strong alignment with EU regulation; CE marking required |
Compliance is evaluated at the level of homogeneous material within each component. Each material type (plastic part, metal housing, solder, cable insulation, etc.) must comply with the concentration limits.
That means not just “overall product weight,” but even small sub-components or materials need to be checked/documented.
There is no universal RoHS certificate issued by the European Commission or another central EU authority. Companies sometimes use the term “RoHS certificate” to describe a supplier declaration, test report or compliance statement.
For finished electrical and electronic equipment subject to EU RoHS, the manufacturer must conduct the applicable conformity assessment, prepare technical documentation, issue an EU Declaration of Conformity and affix the CE marking. A supplier certificate alone does not demonstrate compliance unless its scope, products, restricted substances, applicable exemptions and supporting evidence are clearly identified.
An EU Declaration of Conformity for equipment subject to RoHS should identify:
When several EU laws apply to the same product, manufacturers may prepare a single EU Declaration of Conformity covering all applicable legislation.
EN IEC 63000:2018 provides a framework for preparing technical documentation to assess electrical and electronic products against substance restrictions. It supports a documentary approach based on supplier information, material declarations and other technical evidence.
The IEC 62321 series provides methods for sampling, screening and determining certain substances in electrotechnical products. The appropriate method depends on the substance and material being evaluated. For example, X-ray fluorescence can screen certain elements, but additional chemical analyses may be necessary to identify compounds or substances that XRF cannot directly determine. European Commission, IEC 62321
“RoHS 1” commonly refers to the original Directive 2002/95/EC, which restricted six substances.
“RoHS 2” refers to the recast Directive 2011/65/EU. It expanded and clarified the scope and introduced requirements concerning conformity assessment, technical documentation, the EU Declaration of Conformity and CE marking.
“RoHS 3” is an informal industry term commonly used for Commission Delegated Directive (EU) 2015/863, which added four phthalates—DEHP, BBP, DBP and DIBP—to Annex II. It is not a separate consolidated RoHS regulation. The current legal requirements should be determined using Directive 2011/65/EU as amended. Directive 2011/65/EU, Directive (EU) 2015/863
RoHS does not prescribe one specific solder alloy. It generally limits lead to 0.1% by weight in each homogeneous material, unless a valid exemption applies.
Lead-free alternatives include tin-silver-copper and tin-copper alloys. However, using lead-free solder does not make the entire product RoHS-compliant because every relevant homogeneous material must be evaluated against all applicable restricted substances.
Some categories are often excluded, for instance, batteries, packaging, or certain industrial/automotive/aviation/military equipment, depending on the national transposition of the directive.
Compliance is evaluated at the level of homogeneous material within each component. Each material type (plastic part, metal housing, solder, cable insulation, etc.) must comply with the concentration limits.
That means not just “overall product weight,” but even small sub-components or materials need to be checked/documented.
Non-compliance can lead to enforcement actions: recalls, product withdrawals, fines, or legal penalties, depending on the member-state implementation laws.
Manufacturers/importers must keep records on file to demonstrate due diligence in case of inspection: technical file, declarations from suppliers, and test results.
Also, spare parts and replacement/after-market parts may have different compliance or exemption requirements.
Common challenges include:
Especially for small or medium-sized companies, this cost and paperwork burden can be particularly heavy.
It depends. Even when components were purchased earlier, the finished product must meet the requirements applicable when it is placed on the market. Components that no longer comply following a regulatory change or the expiry of an exemption may therefore make the finished product non-compliant. Effective inventory control and supplier traceability are essential.
Yes. As materials, technologies and scientific knowledge evolve, authorities may add restricted substances, tighten concentration limits or expand the regulatory scope. Companies should therefore monitor applicable requirements and regularly review their compliance documentation.
Need help demonstrating RoHS compliance? Contact Enviropass for expert guidance, documentary assessment and targeted testing tailored to your markets.