If you’re exporting electrical or electronic equipment (EEE) into the European Union, then you need to know about the Restriction on Hazardous Substances directive or RoHS. That’s because most types of EEE are regulated to control the levels of certain hazardous substances and chemicals they contain, with the aim of protecting human and animal health.
Knowing what is a RoHS compliant product is the best way to protect against costly recalls, penalties and damage to your reputation. In this guide we’ll break down RoHS compliance, Why RoHS is important, how to get RoHS compliance, how to get a RoHS certificate, RoHS testing and much more.
What’s the meaning of RoHS compliance in short:
- What it covers: RoHS applies to electrical and electronic products, including appliances, gadgets, and industrial equipment.
- What’s required: The regulation restricts harmful substances like lead and mercury in these products. Manufacturers must ensure their products meet these standards though RoHS compliance testing.
- Where it applies: RoHS started in the European Union but is now required in many places, including the EU, UAE, China, Japan, South Korea, India, and some U.S. states like California. Not following these rules can lead to penalties.
What is RoHS?
In the modern world, the widespread use of electrical and electronic products like mobile phones, computers, and kitchen appliances, leads to a lot of waste. During the collection, treatment, and disposal of these products, toxic substances like lead, mercury, and cadmium can be released, causing big environmental and health issues.
To tackle these challenges, the European Union introduced the Restriction of Hazardous Substances (RoHS) Directive. This directive aims to regulate the use of certain substances that can pose risks to human health and the environment. It was first introduced on July 1st, 2006, originally regulating six harmful substances. It was later updated to include four additional phthalates, bringing the total to ten restricted substances.
All products with electrical and electronic components, unless specifically excluded, must comply with these restrictions and be RoHS tested to be placed on the EU market.
Which products are covered by RoHS?
If you’re a manufacturer, importer, or distributor of Electrical and Electronic Equipment, you need to know what are RoHS products There are specific categories of products that must comply with RoHS regulations. Let’s break them down:
- Toys and Recreational Equipment: Electronic toys, gaming consoles, and other devices designed for entertainment purposes must comply with RoHS to ensure safety, especially for children.
- Consumer Electronics: This includes things like smartphones, tablets, laptops, TVs, digital cameras, gaming consoles, and DVD players. If you’re making or selling any of these products, they need to be RoHS compliant.
- Household Appliances: Appliances like refrigerators, washing machines, vacuum cleaners, and microwaves all fall under RoHS. These items must comply with the regulations to be sold in the EU.
- Industrial Equipment: Many types of industrial equipment, such as machinery, control systems, and other manufacturing tools that contain electrical or electronic components, are also covered by RoHS.
- Medical Devices: Medical devices like imaging systems, diagnostic equipment, and patient monitors are required to be RoHS compliant to ensure safety for both patients and healthcare professionals.
- Telecommunication Equipment: Devices like routers, switches, and other network-related equipment must meet RoHS requirements as well.
- Automotive Electronics: If your product is part of a vehicle, such as in-car entertainment systems, navigation systems, or engine control units, it will need to comply with RoHS.
- Lighting Products: LED bulbs and fluorescent lamps, are also subject to RoHS regulations.
- Any other products that have not been mentioned above and are listed in the RoHS directive.
By knowing what are RoHS products you can better navigate the rules and regulations of the European Union.
Which products are exempt from RoHS?
While RoHS regulations cover a wide range of products, there are some exemptions that apply. The following types of equipment, cables, and spare parts are exempt from RoHS compliance:
- Military Equipment: Products specifically designed for military use or equipment intended for use in space are exempt from RoHS.
- Products Integral to Non-Covered Equipment: Items that are integral to equipment not covered by the regulations do not need to comply.
- Large-Scale Tools and Installations: Large-scale stationary industrial tools and large-scale fixed installations are exempt.
- Solar Panels: Photovoltaic (solar) panels that are produced for permanent use at a specific location are not subject to RoHS regulations.
- Means of Transport: Means of transport, except for certain two-wheeled electric vehicles, are exempt.
- Non-Road Mobile Machinery: Machinery specifically intended for professional use that is not used on roads is exempt.
- Research and Development: Products specifically for research and development that are available on a business-to-business basis are exempt.
- Pipe Organs: Pipe organs are exempt due to their unique components.
- Active Implantable Medical Devices: Devices such as pacemakers and other active implantable medical devices are exempt from RoHS.
What are RoHS restricted substances?
The RoHS Directive sets the maximum allowable concentrations of these hazardous substances by weight:
- Lead (Pb): < 0.1%
- Mercury (Hg): < 0.1%
- Cadmium (Cd): < 0.01%
- Hexavalent chromium (Cr6+): < 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%
These substances are often used during manufacturing processes, and if not controlled, they can pose serious health risks through inhalation or other forms of exposure.
RoHS directives: RoHS 2 and RoHS 3
RoHS has evolved over time to keep up with technological and environmental advancements. Currently, we have:
- RoHS 2: In 2011, the original RoHS directive was revised into RoHS 2, expanding the scope to include more product categories and adding extra responsibilities for manufacturers, importers, and distributors.
- RoHS 3: In 2019, RoHS 3 took things further by adding four more restricted phthalates: DEHP, BBP, DBP, and DIBP.
To dive deeper into RoHS, check out this Complete Guidance for RoHS Compliance in the EU
RoHS labeling requirements
Products covered under the RoHS directive need to carry a CE marking, which means the product meets all relevant EU requirements, ensuring restricted substances are within limits. Labels should be placed where they can be easily seen and must include:
- Product identification (type, batch, or serial number)
- Manufacturer/importer details (name, registered trade name, address, and contact information.
Since January 2, 2013, the CE mark is the only symbol that confirms RoHS compliance. Previously, RoHS-compliant products had a RoHS symbol and some manufacturers still include it out of habit, but it’s no longer required.
Where to get a RoHS certificate?
Getting RoHS certified involves a few steps:
1.Testing: Start with on-site or a RoHS testing lab like HQTS to check the levels of the ten restricted substances under RoHS. This could include XRF testing or phthalate solvent extraction testing.
2.Process Audit: Then, there’s a process audit where the manufacturing processes are inspected on-site to make sure they comply with RoHS requirements.
3.Review Documents: You’ll need to review all relevant paperwork, like the Bill of Materials, Technical File, assembly drawings, material declarations, test reports, and certificates from suppliers.
Note- The Technical File should include:
- A general product description and design information
- Risk assessments for materials, parts, and subassemblies
- Compliance information for materials, parts, and subassemblies
- Manufacturing records and documents
- Standards, specifications, and compliance procedures
4.Certification: After a successful audit, you’ll get a RoHS Certificate of Compliance, also called a Certificate of Conformity or Declaration of Conformity.
RoHS Testing
To be RoHS compliant, manufacturers need to provide test reports showing restricted substances are within limits. The first testing method is usually X-ray Fluorescence (XRF), done following ASTM F2617. This can be done using bench-top or handheld analyzers, with portable handheld analyzers often used first to check high-risk parts.
For RoHS 3, four new phthalates were added to the restricted list, so extra testing is required from a RoHS testing lab. This involves solvent extraction to measure the phthalates, followed by analysis using Gas Chromatography (GC/MS or GC/FID).
With our own in-house labs HQTS is ready to help you comply with RoHS regulations so your products can enter the EU without delays or costly recalls. Contact our dedicated team to find out more.
What are RoHS Exemptions?
RoHS exemptions allow certain products to continue using restricted substances under specific conditions. These exemptions exist because, when new regulations are introduced, companies often need time to adapt their designs and processes without compromising safety, performance, or affordability.
There are two main types of RoHS exemptions:
- Technical Exemptions: These apply when it’s simply not possible to remove a restricted substance because no effective substitute exists yet.
- Time-Limited Exemptions: These are temporary exemptions, allowing companies to use restricted materials for a limited time while they work on finding compliant alternatives. Once the exemption period ends, they’re expected to make the switch.
China RoHS
China has its own version of RoHS, called China RoHS 2, which came into effect on July 1, 2016. This regulation is similar to the EU’s RoHS 2, but with a few key differences. Here’s a simple rundown:
What is China RoHS 2?
China RoHS 2, officially known as the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, restricts the same six substances as EU RoHS 2, but it covers a broader range of electrical and electronic products (EEE). This means that products with working voltages up to 1000VAC or 1500VDC need to meet these standards.
Which Products are Impacted?
While the original China RoHS applied only to electronic information products, China RoHS 2 expanded to include nearly all electrical and electronic products—similar to the EU. These categories include communication equipment, household appliances, industrial machinery, lighting, medical devices, and more.
Marking for Compliance
Unlike EU RoHS, which applies concentration limits to products as a whole, China RoHS 2 requires that each material within a product meet the limits for restricted substances. If a product exceeds these limits, it must have a special mark and display an Environmental Protection Use Period—the time during which the product is safe for use without risking environmental harm or user health. This is a unique feature of China RoHS that’s intended to inform consumers of safe usage timelines.
Best Practices for RoHS Compliance
- Partner with compliant suppliers: Work closely with suppliers to ensure all components meet RoHS standards. Suppliers should provide lab test reports to confirm that each component is compliant.
- Keep your documentation organized: Make sure all technical documents, conformity assessments, and test reports are easy to access. Documentation should cover the entire supply chain.
- Regular testing: Carry out regular RoHS testing to prevent non-compliant substances from entering the manufacturing process. Set up strict controls on raw materials to avoid contamination.
- Partner with a RoHS testing service like HQTS: HQTS RoHS testing services ensure your products remain compliant with the latest updates of the directive allowing for smooth entrance into the European Union.
Frequently Asked Questions about RoHS
- Are RoHS and REACH the same?: RoHS and REACH are two different regulations with different goals. RoHS focuses on limiting hazardous substances in electrical and electronic equipment (EEE), while REACH deals with the regulation of chemical substances more broadly.
RoHS and REACH don’t override each other—if they both cover the same substance, the stricter rule applies. Exemptions in RoHS also can’t weaken the protections under REACH.
- What is SASO RoHS?: SASO refers to the Saudi Standards, Metrology, and Quality Organization, which also has its own RoHS regulation. Similar to the EU RoHS directive, it restricts hazardous substances used in electronic and electrical equipment.
- Where is RoHS required?: Many countries, like China, India, and Saudi Arabia, have their own versions of RoHS, with similar restrictions to ensure product safety and environmental sustainability.
To dive deeper into SASO RoHS, check out this guide on SASO RoHS for Saudi Arabia
HQTS RoHS Services
With HQTS, you get straightforward, reliable support to keep your EEE products compliant and market-ready. From on-site ROHS lab testing to thorough documentation reviews and process audits, our team simplifies every step of achieving RoHS compliance.
We can help with:
- Household Appliances
- IT and Communications Equipment
- Consumer Equipment
- Lighting Products
- Electrical and electronic tools
- Toys, leisure and sports equipment
- And More
It’s the best way to make sure you avoid costly delays, prevent compliance issues, and streamline your path to global markets. Contact our dedicated team to find out more about RoHS compliance today.
