RoHS (Restriction of Hazardous Substances)
RoHS (the EU's Restriction of Hazardous Substances Directive, 2011/65/EU) restricts ten substances — lead, mercury, cadmium, hexavalent chromium, two brominated flame retardants, and four phthalates — in electrical and electronic equipment placed on the EU market. It applies by default to nearly all EEE across eleven product categories, from household appliances to medical devices and their cables, unless a specific exemption applies. RoHS compliance is a prerequisite for CE marking most electronic products for EU sale, and it is often confused with REACH, which is a separate, broader chemical regulation covering far more than electronics.
What RoHS restricts, and at what threshold
RoHS sets a maximum concentration for each restricted substance, measured per homogeneous material — a single material that can't be mechanically separated into different materials, not the finished product as a whole. A cable assembly is assessed material by material: the copper conductor, the plastic jacket, and the solder joints are each checked against the limit independently.
| Substance | Maximum concentration |
|---|---|
| Lead | 0.1% by weight |
| Mercury | 0.1% by weight |
| Cadmium | 0.01% by weight |
| Hexavalent chromium | 0.1% by weight |
| PBB / PBDE (flame retardants) | 0.1% by weight |
| DEHP, BBP, DBP, DIBP (phthalates) | 0.1% by weight |
The four phthalates were added later, sometimes referred to informally as "RoHS 3," and are the most recent substances to be folded into the directive's scope.
Scope: which products need it
RoHS covers eleven categories of electrical and electronic equipment (EEE): large and small household appliances, IT and telecom equipment, consumer equipment, lighting, electrical and electronic tools, toys and leisure equipment, medical devices, monitoring and control instruments, automatic dispensers, and — as a catch-all — any other EEE not covered elsewhere, plus cables and components used within covered equipment.
A product needs specific exemption to avoid RoHS rather than the reverse: coverage is the default for EEE, and exemptions (military equipment, spare parts for equipment placed on the market before RoHS applied, certain lead-in-solder use cases) are the narrow exception. Exemptions are also time-limited and periodically reviewed — several lead-related exemptions have tightened or approached expiry in recent renewal cycles, so a product's compliance basis can shift even when its design hasn't changed.
RoHS vs REACH vs WEEE
These three EU rules travel together in compliance documentation, which is exactly why they get merged in people's heads. They aren't the same thing.
| Rule | What it governs | Scope |
|---|---|---|
| RoHS | Ten specific hazardous substances | Electrical and electronic equipment only |
| REACH | Chemical registration, evaluation, and restriction broadly | Virtually any physical product, not just electronics |
| WEEE | Collection, recycling, and disposal of end-of-life electronics | Electrical and electronic equipment only |
A product can be fully RoHS-compliant and still carry REACH obligations — RoHS says nothing about a substance that isn't on its ten-item list, however hazardous, and REACH applies to the plastic housing and metal fasteners of a RoHS-covered product just as it would to any non-electronic item made of the same materials.
What this means for product data
For a distributor or manufacturer, RoHS compliance is typically a per-SKU boolean or enumerated field ("RoHS compliant" / "RoHS exempt, category X" / "not RoHS applicable") backed by a Declaration of Conformity document, managed the same way an SDS is: as a linked document tied to the SKU or to a shared component/formulation, not authored fresh per listing. It sits in the same compliance-attribute cluster as GHS classification and Prop 65 status, but answers a narrower, EU-specific question — none of those three fields can be inferred from the others.
Frequently asked questions
What does RoHS stand for?
Restriction of Hazardous Substances. It refers to EU Directive 2011/65/EU, which restricts ten hazardous substances in electrical and electronic equipment sold in the EU.
What is the maximum lead content allowed under RoHS?
0.1% by weight (1,000 ppm) in any homogeneous material within the product. Cadmium has a stricter limit of 0.01% by weight; the other eight restricted substances share the 0.1% threshold.
Is RoHS the same as REACH?
No. RoHS restricts ten specific substances in electrical and electronic equipment only. REACH is a much broader EU chemical regulation covering registration, evaluation, and restriction of chemicals across virtually any physical product. A product can satisfy one and still have obligations under the other.
Does RoHS apply outside the European Union?
RoHS itself is EU law, but several other jurisdictions have adopted similar restrictions modeled on it, commonly referred to informally as "RoHS-equivalent" rules (for example, China's electronic-information-products hazardous-substance regulations). These are separate legal instruments with their own scope and thresholds, not automatic extensions of the EU directive.
Do RoHS exemptions expire?
Yes. Exemptions, including several covering lead use in specific applications, are granted for limited periods and reviewed for renewal or removal on an ongoing basis, so a product's exemption basis can lapse even without any change to its design.