Understanding what is RoHS and how to achieve RoHS compliance is critical for any company manufacturing or importing EEE. This page explains the RoHS meaning, outlines the requirements, and shows how to become RoHS compliant under the global regulations.
Enviropass is here to assist you with your testing towards product environmental compliance worldwide
Key RoHS requirements include:
This is an acronym that stands for Restriction Of Hazardous Substances. The long version is the Restriction of the use of certain hazardous substances.
Or simply put, what is the scope? These regulations target Electrical and Electronic Equipment (EEE). Depending on the countries, the covered product categories differ. The EU probably has the broadest scope, covering most household, professional, medical devices, tools, monitoring instruments, and even industrial products.
Generally speaking, aerospace, military, and automotive products are out-of-scope. Batteries obligations and package requirements are also excluded. However, specific regulations apply to automotive equipment (ELV), batteries, and packaging environmental compliance.
First of all, most RoHS regulations mirror the European ones all over the world. This is the case of the Eurasian Economic Union, the United Arab Emirates, Turkey, California, and other states and countries. Unlike the European Union, some countries like the United Arab Emirates request external audits.
Significant national deviations apply to other regulations, like in China and Taiwan, with different sets of labels and declarations.
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.
Depending on the jurisdiction, amendments to the rules differ. For example, in the EU, more than 50ish amendments, modifications, or updates since the 1st release. Some amendments are major, like the 2015/863 one with the addition of the four restricted phthalates.
In short, not only. It is true that environmental concerns in electronics have started with lead. However, despite lead and its compounds being the most prevalent restricted substances in electronics, other heavy metals, brominated substances, and phthalates also matter.
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.
Electronics typically contain hazardous substances. They may be harmful to both human beings and the environment. For example, several chemicals used in most devices are carcinogenic, reprotoxic, and/or bioaccumulative. Importantly, at the end of a product’s lifespan, what will we do with toxic e-waste, also called WEEE? It may be very costly and difficult to depollute and recycle the electronics. Therefore, it becomes critical to work from the design stage and avoid as many hazardous substances as possible.
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.
In short, no. The scopes, restrictions, and targetted substances differ. Even though both regulations may apply to the same product, in the same jurisdiction, there are various differences between RoHS and REACH. For instance, while RoHS is specific to electrical and electronic equipment, REACH applies to almost any article, mixture, and substance!
In essence, you will have to confirm that none of the targeted hazardous substances exceed their threshold of 0.1% (or 0.01% for cadmium) at the homogeneous material level of every component and material in your product. Two approaches are available:
The latter is highly recommended for complex products. When conducted, it should meet the IEC 63000 standard.
With the Enviropass lab in Montreal, we have developed a unique solution offering the best worlds of both documentary and analytical testing approaches.
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 | Follows EU model but administered under UK law; UKCA marking instead of CE (transition periods apply) |
China RoHS | All EEE listed in the “Catalogue for the Administration of the Restriction of Hazardous Substances in EEE” | Requires labeling under the Environmental Protection Use Period (EPUP); compulsory testing only for catalog-listed products |
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. | Labeling requirement only (green/orange marks); substance restriction is voluntary |
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. Phthalates not restricted | Different exemption codes and 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.
Some categories are often excluded, for instance, batteries, packaging, or certain industrial/automotive/aviation/military equipment, depending on the national transposition of the directive.
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.
Analytical test methods would include chemical analyses such as X-ray fluorescence (XRF) for heavy metals, or other lab-based detection for phthalates/brominated flame-retardants.
Alternatively, documentary-approach methods can be used for complex products or large supply chains, supplier declarations, and material certifications-although there is some risk with this approach if suppliers are not rigorous.
Common challenges include:
Especially for small or medium-sized companies, this cost and paperwork burden can be particularly heavy.
It depends. Even if components are procured earlier, if the final product is placed on the market at a time when more stringent RoHS provisions apply (or after exemption expiry), using old non-compliant components may result in non-compliance. Careful stock control, labeling, and supplier traceability are important.
Yes. It would be expected that, as the usage of new materials and chemicals evolves, the list of restricted substances could expand, limits may become stricter, and regulatory scope may broaden. Some jurisdictions already consider or implement updates. This trend is driven by advances in detection technology, growing environmental/health concerns, and the push for greener electronics/ecodesign.
Other States, like Brazil, have also drafted similar regulations. The Brazilian Ministry of the Environment has published RoHS Brazil.
Need help ensuring your products are RoHS compliant? Contact Enviropass for expert guidance and testing to meet your global requirements.