What Is RoHS?

The RoHS (Restriction of the use of certain Hazardous Substances) Directive restricts six substances that can be used in new electronic & electrical equipment (EEE) sold within/to European Union countries after July 1, 2006. This is a European Union (EU) directive however it affects companies worldwide.

From this date, products included in eight initial categories of electrical and electronic equipment were not able to be sold sell in the EU if they contain six banned substances at concentrations above the maximum concentration values allowed unless specific exemptions apply.

The product categories are:

  • Large household appliances
  • Small household appliances
  • IT and telecommunications equipment
  • Consumer equipment
  • Lighting equipment
  • Electrical and electronic tools (except large scale stationary industrial tools)
  • Toys, leisure and sports equipment
  • Medical Devices (RoHS Recast)
  • Monitoring and Control Instruments (RoHS Recast)
  • Automatic dispensers
  • Other EEE not covered by any other category (RoHS Recast)

The six restricted substances are:

  • Lead (Pb) (0.1%)
  • Mercury (Hg) (0.1%)
  • Hexavalent chromium (CR(VI)) (0.1%)
  • Cadmium (Cd) (0.01%)
  • Polybrominated biphenyl flame retardants (PBB) (0.1%)
  • Polybrominated diphenyl ether flame retardants (PBDE) (0.1%)

Restricted substances – where they might be found


Termination coatings on components
Paints as pigments and as driers
PVC as a stabilizer
Batteries (not covered by RoHS directive)


Electroplated coatings
Special solders (eg in some types of fuses)
Electric contacts, relays, switches
PVC stabilizer
Plastics, glass and ceramic pigments
In some glass and ceramic materials



Hexavalent chromium

Passivation coatings on metals
In corrosion resistant paints


Flame retardants in plastics

Why is this important for suppliers and distributors?

Although this is a European based law, RoHS-Style laws have taken affect in China, Japan, South Korea, and California in the United States.

Manufacturers must design, build, and identify parts with these RoHS regulations in mind. The entire supply chain must be able to distinguish RoHS compliant parts from non-compliant parts.

Do we have to report the RoHS status of our parts?

Although, in most cases, the RoHS regulations apply to the finished product, the manufacturer needs to know the content of all the parts within the final product. Thus, companies within the supply chain need to provide the information. IPC ( has created an industry standard form for reporting RoHS materials content titled IPC-1752A Materials Declaration Management with Amendments 1 & 2.

RoHS recast

On July 1, 2011 the EU voted to accept changes to the RoHS regulations. This RoHS Recast has several significant changes. Added to the scope of the original product categories is:

  • Medical devices (category 8)
  • Monitoring and control instruments (category 9)
  • In-vitro diagnostic medical devices will be phased in from July 22, 2016,
  • Industrial monitoring and control equipment will follow from July 22, 2017
  • Introduction of a category 11, all products not captured in categories 1 to 10, will be phased in by July 22, 2019.

Definition change

Originally, EEE was defined as "dependent on electric current or electromagnetic fields for its primary function‟, with the word “primary” being of most importance. RoHS 2 changes the definition to "dependent on electric currents or electromagnetic fields to fulfil at least one intended function‟. So for example, a gas cooker with an electric clock, previously out of scope, would now be captured by category 11. However, there are several exclusions including military equipment, means of transport, photovoltaic panels and research and development equipment only available on a B2B basis.


There have been exemptions granted for various product for various reasons. There had been a four year exemption review period that has been replaced by the automatic expirationof exemptions, unless they are renewed. Categories 1 to 7 and 10 will be valid for a maximum of five years, while categories 8, 9 and 11 will be valid for seven years.

CE mark and my components

On the January 2, 2013, all products sold on or after this date and which are in the scope of RoHS will be subject to CE obligations (Must have a CE mark). Typical CE requirements requested as part of the "goods package‟ within RoHS 2 are designed to verify that products meet required CE marking and documentation requirements.

These include:

  • Undertaking audits
  • Producing declarations of conformity
  • Technical files
  • Product CE marking
  • Product labeling

The CE mark applies primarily to completed products rather than components.

For more information contact: Staff: Barney Martin, VP of Industry Practices