INFORMATION ABOUT RoHS

What is the RoHS Directive?

The RoHS Directive was issued by the European Union. RoHS stands for “Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment”. The Directive aims to place restrictions on the use of these hazardous substances in order to protect human health and the environment, and to improve recycling. You can find the complete version of European Directive 2011/65/EU (latest consolidated version dated April 1, 2021) with all annexes here. There have been a number of new versions and amendments since the Directive was first issued. 

Germany transposed the RoHS Directive into national law with the Ordinance Restricting the Use of Hazardous Substances in Electrical and Electronic Equipment (ElektroStoffV). In Austria, the Ordinance on Waste from Electrical and Electronic Equipment (Elektroaltgeräteverordnung) has been in force since 2005. Non-European Union countries also have introduced comparable legislation to enforce compliance: Switzerland and Lichtenstein (Chemical Risk Reduction Ordinance), China (China-RoHS) and South Korea (Korea-RoHS), for instance.

RoHS compliance primarily affects manufacturers and importers of electrical and electronic equipment in the European Union. It was introduced to restrict the use of substances in electrical and electronic equipment. materials and components that are very harmful to the environment or human health. Toxic components of particular concern, such as lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ethers (PBDE), are prohibited in products up to a low threshold (0.1 per cent by weight).

In addition, the RoHS Directive prohibits lead soldering in electronic components and toxic flame retardants in cable production. This means the RoHS Directive directly affects importers and other businesses, retail chains and ultimately the consumer in the European economic area too. Many production methods and articles that were once commonplace are no longer permitted as a result of the Directive. However, there are also exemptions to the restrictions for some substances that are used in certain products.

The use of lead-free solder poses a particular challenge for the automotive industry and other sectors. Alternative solders containing silver are more expensive, so manufacturers have to decide whether to compromise on quality. To date, a series of exemptions apply to take into account this loss of quality, including exemptions for the medical and military sector as well as automotive electronics. For example, an exemption exists that still permits the use of lead in vehicle booster batteries. The limit for lead in copper alloys permits up to four per cent by weight. These kinds of exemptions are checked regularly and may also expire. 

Substance bans may be imposed for alternative substances without a comprehensive risk assessment – all it takes is for there to be a potential risk to people and the environment.

Implementation of the RoHS Directive is further complicated by the fact that these exemptions do not apply consistently throughout the European Union – some nation states allow special provisions. For instance, car radios that are sold in retail outlets in the Netherlands are covered by the Directive. This is not the case in other countries. Special provisions like these can pose major problems for developers if they market their products in more than one EU country. They constantly need to be aware of new exemptions. Applications for exemptions may take several years to gain approval. 

The following ten substances are restricted by the RoHS Directive. The maximum permitted concentration tolerated in homogeneous materials is given in brackets as a percentage by weight.

  • lead (0.1%)
  • mercury (0.1%)
  • cadmium (0.01%)
  • hexavalent chromium (0.1%)
  • polybrominated biphenyl (PBB) (0.1%)
  • polybrominated diphenyl ethers (PBDE) (0.1%)
  • Di(2-ethylhexyl)phthalate (DEHP) (0.1%)
  • butylbenzylphthalate (BBP) (0.1%)
  • dibutylphthalate (DBP) (0.1%)
  • diisobutylphthalate (DIBP) (0.1%)

There are exemptions from these upper thresholds that are described in greater detail in Annex III of Directive 2015/863/EU. Annex III is updated about every four years.

According to Annex I, all European businesses that manufacture the following equipment or components which make up part of them are affected by the RoHS Directive:

  • large domestic appliances
  • small domestic appliances
  • IT and telecommunications devices
  • consumer electronics equipment
  • lighting equipment
  • electrical and electronic tools
  • toys, sports, and leisure equipment
  • medical devices
  • monitoring and control instruments including industrial monitoring, and control instruments
  • automatic dispensers
  • other electrical and electronic equipment that is not classed in one of the above-mentioned categories

The CE marking and conformity assessment were introduced in 2011. This means that manufacturers need to display an EU Declaration of Conformity, affix CE marking to equipment, ensure permanent conformity and observe specific obligations for documentation and duty of disclosure.

The WEEE Directive (Waste Electrical and Electronic Equipment Directive), which came into force in 2003, works in tandem with the RoHS. It is a recast of the Waste Electrical and Electronic Equipment Directive 2012/19/EU. The WEEE Directive aims to avoid and reduce electrical waste and to make its disposal environmentally friendly by achieving annual recycling rates of at least four kilograms of electrical waste per European Union resident.

Unlike the REACH Chemicals Regulation, RoHS restrictions for substances only cover products to which WEEE applies, in other words, components in electrical and electronic equipment. The scope of the REACH Regulation is more extensive. It also applies to other industry sectors such as textiles, toys and automotive, and covers more than just restrictions for substances. However, as REACH also applies to the electronics sector and covers numerous chemicals that are also used in electronic components, there are several overlaps between REACH and RoHS.

Original Directive 2002/95/EC Restricting the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS I, 2003):

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Directive 2011/65/EU enacted by the European Parliament and the European Council, dated June 8, 2011, Restricting the Use of Certain Hazardous Substances in Electrical and Electronic Equipment:

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Commission Delegated Directive (EU) 2015/863 amending Annex II of the RoHS Directive 2011/65/EU (March 2015):Link

Directive (EU) 2017/2102 amending Directive 2011/65/EU:

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Directive 2011/65/EU (last consolidated version dated 04/01/2021):

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MORE INFORMATION ABOUT RoHS

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