RoHS · Directive 2011/65/EU
RoHS Compliance Explained: What It Restricts and Who It Applies To
RoHS is not part of CE marking, and it is not the same law as China RoHS despite sharing a name and a similar substance list. If your product has any electrical or electronic function, RoHS is very likely a separate, independent obligation — here is exactly what it restricts, who is responsible, and what "RoHS compliant" actually has to mean.
RoHS at a Glance
- Legal basis: Directive 2011/65/EU (RoHS 2, the "recast"), directly enforced across the EU
- Applies to: Electrical and electronic equipment (EEE) — 11 defined product categories
- Core obligation: Keep restricted substances below set concentration limits, and prove it
- Not the same as: CE marking, REACH, or China RoHS — each is a separate obligation
Quick answer: RoHS (Directive 2011/65/EU) restricts ten hazardous substances — including lead, mercury, cadmium and several phthalates — in electrical and electronic equipment sold into the EU. It applies independently of CE marking: a product can need both, and satisfying one does not satisfy the other. There is no single universal "RoHS certificate" — compliance is demonstrated through test reports against the substance limits and a technical file the manufacturer holds, similar in structure to CE marking's Declaration of Conformity. EU RoHS is also a separate law from "China RoHS," which restricts a similar but not identical substance list under different rules.
What RoHS Actually Restricts
Ten Substances, Specific Limits, No Exceptions Without Justification
RoHS does not ban electrical and electronic equipment containing these substances outright — it sets a maximum concentration limit for each, measured by weight in a homogeneous material (meaning each individual material in the product, not the product as a whole, has to stay under the limit). Exceeding the limit in even one component can make the entire product non-compliant, which is why RoHS testing is done at the material level, not just on the finished assembly.
"Homogeneous material" is doing a lot of work in that definition, and it is worth being precise about it: it means a material that cannot be mechanically separated into different materials — a single layer of plating on a screw, the plastic housing of a connector, or the solder joining two components each count as their own homogeneous material, even though they are all part of the same finished product. A product with dozens of distinct materials needs each one individually assessed, which is why RoHS compliance files for complex electronics can run to dozens of line items even for a single product.
The ten restricted substances have stood since the original 2011 recast, with four phthalates added later via a 2015 amendment that became enforceable from 2019 — a detail that trips up anyone relying on an outdated substance list.
The Substance List
The 10 RoHS-Restricted Substances and Their Limits
| Substance | Maximum concentration |
|---|---|
| Lead (Pb) | 0.1% |
| Mercury (Hg) | 0.1% |
| Cadmium (Cd) | 0.01% |
| Hexavalent chromium (Cr VI) | 0.1% |
| Polybrominated biphenyls (PBB) | 0.1% |
| Polybrominated diphenyl ethers (PBDE) | 0.1% |
| Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% |
| Benzyl butyl phthalate (BBP) | 0.1% |
| Dibutyl phthalate (DBP) | 0.1% |
| Diisobutyl phthalate (DIBP) | 0.1% |
Cadmium's limit is ten times stricter than the other nine substances — a common detail that generic "RoHS limit" summaries flatten into one number when it genuinely is not one number.
The 10 Substance Limits, Visualised
Maximum concentration by weight, per homogeneous material. Cadmium's bar is a tenth the height of the rest.
Source: Directive 2011/65/EU, Annex II.
Scope
Which Products Actually Need RoHS Compliance
In scope
Equipment dependent on electric currents or electromagnetic fields to work properly — the 11 categories span large and small household appliances, IT and telecoms equipment, consumer electronics, lighting, electrical/electronic tools, toys with electronic parts, and several others.
Commonly missed as in-scope
Cables and components sold separately, chargers and power supplies, and electronic sub-assemblies destined for a larger product — RoHS can apply to a component even before it reaches the finished product it will be part of.
Generally out of scope
Large-scale fixed installations, military equipment, and equipment designed exclusively for research and development not made available on the market — narrow exclusions, not a general opt-out for "professional" or "industrial" framing alone.
The 11 defined EEE categories: large household appliances · small household appliances · IT and telecommunications equipment · consumer equipment · lighting equipment · electrical and electronic tools · toys, leisure and sports equipment · medical devices · monitoring and control instruments · automatic dispensers · other EEE not covered above.
Exemptions
RoHS Exemptions Are Specific, Not General
RoHS allows narrow, technically justified exemptions — where a substance is currently unavoidable for a specific application — listed in the directive's annexes, not a blanket "if it's technically difficult" excuse.
How an exemption actually works
Each exemption is scoped to a specific application (for example, certain lead content in specific solder alloys for defined uses), has its own expiry/review date, and has to be actively claimed and justified — it is not assumed to apply just because a similar product elsewhere uses it.
Why this matters for sourcing
A component supplier claiming "RoHS exempt" needs to specify exactly which annex exemption and why it applies to your specific use — a vague exemption claim with no annex reference is a documentation gap, not evidence of compliance.
The exemptions live in two separate annexes with different scope: Annex III covers general exemptions applicable across all 11 EEE categories; Annex IV covers exemptions specific to medical devices and monitoring/control instruments only. An exemption listed under Annex IV does not apply to a general consumer electronics product just because the substance and application look similar — check the correct annex, not just the substance name.
The Certificate Myth
There Is No Single Universal "RoHS Certificate"
Exactly like CE marking, RoHS has no central EU body that issues one certificate covering a product for all purposes. What actually demonstrates compliance is a combination of test reports (from an accredited lab, testing each material against the ten substance limits) and a Declaration of Conformity the manufacturer signs, referencing that evidence. A "RoHS certificate" that a factory includes with a shipment is only meaningful if it is backed by real test reports for your specific product's actual materials — a generic document reused across unrelated products is not RoHS compliance, whatever it is labelled.
This is also where the EU RoHS / China RoHS confusion causes real problems: China RoHS (GB/T 26572, sometimes called "China RoHS 2") restricts a similar but not identical substance list, under a different marking and disclosure system aimed at the Chinese market. A product certified against China RoHS is not automatically EU RoHS compliant, and vice versa — the overlap is substantial but the two are legally separate regimes with separate evidence requirements.
EU RoHS vs China RoHS
Two Different Laws That Happen to Share a Name
| EU RoHS | China RoHS | |
|---|---|---|
| Legal basis | Directive 2011/65/EU | GB/T 26572 (management measure, not an EU-style directive) |
| Compliance route | Self-declaration backed by test evidence — no mandatory pre-market certification | Marking/labelling regime, with phased mandatory pre-market testing for listed product categories |
| Substance list | Fixed at 10 substances since the 2019 phthalate amendment | A similar core list, but scope and thresholds are set and revised separately from the EU list |
| Market covered | European Union | Mainland China |
Selling into both markets means satisfying both regimes independently — passing one is meaningful evidence to start from, but it is not, by itself, proof of the other.
The Process
How RoHS Compliance Actually Gets Demonstrated
Identify every homogeneous material
Break the product down to the material level — each plastic, solder, coating and sub-component individually — since the concentration limits apply per material, not to the assembled product as a whole.
Test or gather supplier declarations for each material
Accredited lab testing (typically XRF screening plus confirmatory testing where needed) is the strongest evidence; supplier material declarations can support this but do not replace testing for the materials that actually carry risk.
Claim any genuinely applicable exemption, by annex reference
Where a substance is present but a specific RoHS exemption genuinely applies, document exactly which exemption and why — not as a blanket assumption.
Compile the technical file and sign the Declaration of Conformity
The technical documentation and Declaration of Conformity sit alongside — and are often integrated with — the CE-marking technical file for the same product, since both typically apply together for electronics.
RoHS vs REACH vs CE Marking
Three Regimes That Commonly Apply to the Same Product
| RoHS | REACH | CE Marking | |
|---|---|---|---|
| What it covers | 10 restricted substances in electrical/electronic equipment specifically | Broader chemical-substance registration and restriction, all product types | Essential safety/performance requirements for harmonised categories |
| Applies to | Electrical and electronic equipment only | Any product containing regulated chemical substances | Electronics, machinery, toys, PPE and other harmonised categories |
| Core evidence | Material-level test reports + Declaration of Conformity | SVHC declarations, registration where thresholds are met | Declaration of Conformity + technical file |
| Marking on product | No separate RoHS mark — folded into the CE mark's underlying compliance | No product mark — SDS/declaration-based | The CE mark itself |
A single electronic product routinely needs all three at once — RoHS for restricted substances, REACH for broader chemical compliance, and CE marking for the directive-specific safety and performance requirements. None of the three substitutes for the others.
A Pattern We See Often
"Our Supplier Said the Component Was RoHS Compliant"
A common gap: a manufacturer sources a component (a connector, a cable assembly, a small electronic module) with a supplier datasheet stating "RoHS compliant" in a single line, with no test report, no specific substance data, and no indication of which RoHS version or year's substance list it refers to. The manufacturer assembles the final product and includes that component in its own Declaration of Conformity without ever verifying the underlying claim. If a market surveillance authority later requests the technical file, "the supplier said so" is not evidence — the manufacturer, not the component supplier, is the party legally responsible for the finished product's RoHS compliance, regardless of what any individual component's datasheet claims.
The fix: request the actual test report or a specific, dated declaration referencing the current ten-substance list from every material supplier, not just a one-line compliance claim on a datasheet — and treat unverified component-level claims as a gap to close, not evidence already in hand.
Who Is Responsible
RoHS Obligations by Economic-Operator Role
RoHS obligations follow the same economic-operator structure as CE marking, with responsibility concentrated on the manufacturer first.
Manufacturer
Carries the primary obligation: carrying out the substance assessment, holding the technical documentation, and issuing the Declaration of Conformity that covers RoHS alongside any other applicable directives.
Importer
Must verify the manufacturer has actually done the RoHS assessment and holds the required documentation before placing the product on the EU market — not simply take the manufacturer's compliance on faith.
Distributor
A narrower check-and-verify obligation: confirming the required documentation and markings exist, and not knowingly supplying a product known to breach the substance limits.
See our Economic Operators guide for how these roles interact across GPSR, CE marking and RoHS together, since the same party often holds more than one role for the same product.
Cost
What RoHS Testing and Compliance Actually Cost
RoHS testing cost scales with how many distinct materials a product contains, not a flat per-product fee.
XRF screening
The fastest, lowest-cost first-pass test for several of the ten substances — good for triage, but not always sufficient on its own for a full compliance file.
Confirmatory lab testing
More precise, more expensive per material — typically reserved for materials that screen as borderline or where XRF cannot reliably detect a specific substance (notably some of the phthalates).
Ongoing material-change monitoring
A smaller recurring cost for re-verifying materials when a supplier or component changes — RoHS compliance is tied to the specific materials actually used, not a one-time product-level pass.
As with GPSR and CE marking, we do not quote a fixed number here — the Product Compliance Assessment identifies which materials in your specific product actually need testing before you commit budget to a full lab panel.
FAQ
Common Questions About RoHS
Is RoHS the same as CE marking?
No. RoHS restricts specific hazardous substances in electrical and electronic equipment; CE marking covers a broader set of essential safety and performance requirements under separate harmonised directives. Most electronics need both, but they are independent obligations with independent evidence.
Is EU RoHS the same as China RoHS?
No — they are separate national/regional regimes with overlapping but not identical substance lists, different marking and disclosure systems, and different legal bases. Compliance with one does not automatically satisfy the other.
Do I need to test every single component, or can I rely on supplier declarations?
Supplier declarations can support your file, but the finished-product manufacturer holds ultimate legal responsibility for RoHS compliance — a vague or undated supplier claim with no test data behind it is a gap to verify, not evidence you can rely on as-is, particularly for materials with meaningful risk of containing a restricted substance.
What happens if my product fails RoHS testing on one material?
A single non-compliant homogeneous material makes the finished product non-compliant as a whole, even if every other material passes — the fix is substituting or reformulating that specific material, not averaging across the whole product.
Are RoHS exemptions permanent?
No — each exemption in the directive's annexes has its own review and expiry date, and exemptions are periodically reassessed and can be withdrawn as substitute materials become available. Relying on an exemption without checking its current status is a real risk.
Does RoHS apply to spare parts and repair components?
Generally yes for spare parts placed on the market to repair, reuse or upgrade equipment already covered by RoHS, subject to specific conditions in the directive — this is a narrower area worth checking specifically for repair-focused or refurbished-goods businesses.
My product is CE marked — doesn't that already cover RoHS?
Not automatically, though the two are closely linked in practice: RoHS compliance is one of the essential requirements referenced by the Declaration of Conformity for products under the relevant directives, but the underlying material testing has to actually be done — CE marking is not valid evidence of RoHS compliance on its own without that testing behind it.
What is the difference between XRF screening and confirmatory lab testing?
XRF (X-ray fluorescence) screening is a fast, non-destructive first-pass test that can reliably detect several RoHS substances (like lead and cadmium) but cannot reliably detect others, particularly the phthalates. Confirmatory testing uses more precise, typically destructive lab methods for materials that screen as borderline or that XRF cannot adequately assess — most real compliance files use both, not one or the other exclusively.
Does RoHS apply to products I only sell business-to-business, not to consumers?
Yes — RoHS scope is defined by the product category (electrical and electronic equipment within the 11 defined categories), not by whether the end buyer is a business or a consumer. B2B equipment within scope needs the same substance compliance as consumer equipment.
How often does the RoHS substance list change?
Infrequently, but not never — the list has been amended once since the 2011 recast, adding four phthalates with a 2019 enforcement date. Treat any RoHS content (including this page) as needing periodic reverification against the current EUR-Lex text rather than assuming a substance list is permanently fixed.
Do cables and chargers sold separately from the main product need their own RoHS compliance?
Yes — a cable, charger or power supply sold as its own product, or bundled with equipment it will be used with, is itself within RoHS scope as electrical equipment, independent of the compliance status of the device it is meant to power or connect to.
What is the penalty for selling a non-RoHS-compliant product in the EU?
Penalties are set at national level and vary by member state, following a broadly similar pattern to GPSR and CE-marking enforcement: fines that scale with severity, alongside the power to order the product withdrawn from the market. As with the other regimes covered on this site, the more immediate practical consequence for most sellers is commercial — a distributor or marketplace refusing to carry a product that cannot produce RoHS test evidence on request.
Related Regulations
What Else Commonly Applies Alongside RoHS
CE Marking
The broader conformity framework RoHS typically sits alongside for electrical and electronic products.
GPSR
The general product safety baseline that applies to the same electronics independently of RoHS.
Economic Operators
Who is legally responsible for RoHS compliance when you outsource manufacturing or source components.
Where the Facts Come From
Sources for This Page
Directive 2011/65/EU (RoHS 2/recast) and its amending act adding the four phthalates (Tier 1, EUR-Lex) are the primary legal sources for the substance list and limits on this page. European Commission RoHS guidance and FAQ documents (Tier 1–2) were used for scope and exemption-mechanics detail. Where this page describes practical testing sequencing, that is flagged as professional implementation guidance (Tier 3), not a restatement of the legal text.
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