A Complete Guidance for RoHS Compliance in EU

RoHS 3 Compliance

RoHS is an European Union based directive that has affected the global electronics industry. All manufacturers, authorized representatives, importers and distributors of electrical and electronic equipment aiming to import goods into EU must comply with this regulation.

Is my company RoHS 3 compliant in 2020?

RoHS is the EU Directive that restricts the use of hazardous substances in electrical and electronic products (EEE products). RoHS affects any company importing goods containing electrical components into the European Union.

Products compliant with this directive do not exceed the allowable amounts of the following restricted materials: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE), as well as four phthalates of Bis(2-ethylhexyl) Phthalate (DEHP), Benzyl Butyl Phthalate (BPP), Dibutyl Phthalate (DBP) and Diisobutyl Phthalate (DIBP), with some limited exemptions.

What is the purpose of RoHS?

RoHS regulation is legislated by the EU to reduce the environmental effect and health impact of electronics. The legislation’s primary purpose is to make electronics manufacturing safer at every stage of an electronic device’s life cycle.

Am I affected by RoHS?

RoHS applies to all manufacturers, authorized representatives, importers and distributors of electronics and electronic equipment in any restricted product category.

All parties involved in the supply chain of electronics and electronic equipment have a responsibility to ensure that their products comply with all requirements set out in the RoHS directive regulations. They should not only ensure the compliance of finished products, but also component parts which may be ordered and inventoried during the manufacturing process.

RoHS 3 or Directive 2015/863

Directive 2015/863 is also known as RoHS 3, which revises the 2011 and adds restrictions for 4 additional phthalates. Under the new guidelines, mandatory testing is now required for 10 substances that have been banned from the EU.

RoHS 2 vs RoHS 3

The original Directive (Directive 2002/95/EC) originated in the EU in 2002 to restrict six hazardous materials found in electrical products. It went into law on July 1, 2006.

The recast European RoHS Directive (2011/65/EU), known as RoHS 2, has been in force since 2011. This directive also established the CE-marking directive, with RoHS compliance now required for CE marks on products. It also added Categories 8 and 9 for medical devices, monitoring, and control instruments providing for additional compliance requirements.

Finally, Directive 2015/863, known as RoHS 3, went into effect from July 22, 2019 that adds four additional restricted substances for all electrical and electronic equipment. These substances are all phthalates, which are mainly used as insulation plasticizers.

Restricted substances





RoHS product categories

The following categories of products require RoHS testing before they can be sold in the EU:

  1. Automatic dispensers
  2. Consumer equipment
  3. Electrical and electronic tools
  4. IT and telecommunications equipment
  5. Large household appliances
  6. Lighting equipment
  7. Medical devices*
  8. Monitoring devices*
  9. Small household appliances
  10. Toys, leisure and sport equipment
  11. All other electronic devices

*The requirements for medical equipment and monitoring device will be effective from July 22, 2021.

Category 11 includes all other electrical and electronic equipment that are not covered in another category as well as “open scope of application.” This applies to all equipment that meets the definitions of “electrical and electronic equipment”.

RoHS exemptions

The European Commission had published a number of exemptions , including exemptions on the use of Lead, Cadmium, Mercury, Polybrominated biphenyls, Polybrominated diphenyl ethers and Hexavalent chromium for specific purposes.

The restriction of these substances does not apply to toys which are already subject to other restrictions. Toys that fall under the scope of RoHS, restrictions under REACH take precedence.

CE marking

The RoHS regulations require that all new EEE placed on the EU market must carry the CE mark. This is part of the self-certification process and is designed to be a visible demonstration of conformity.

The CE mark indicates compliance not only with RoHS but with all EU legislation. By affixing the CE mark, you take full responsibility for compliance with all EU regulations that apply to your product. To apply the CE mark, you are legally declaring your product is in full compliance with RoHS regulations and that you have the documentation to prove it.

Waste of electrical and electronic equipment (WEEE)

WEEE stands for Waste from Electrical and Electronic Equipment. RoHS regulates the hazardous substances used in the manufacture of EEE, while WEEE regulates the disposal of the same electronics. All applicable products for the EU market must pass WEEE compliance and carry the “Wheelie Bin” mark.

How can I certify that my organization is RoHS compliant?

Organizations often prove RoHS compliance with a Declaration of Conformity, which is a self-declaration that the EEE meets all of the RoHS requirements. By making the declaration, you assume all responsibility for compliance with the regulations. The DoC must include identifying information about you and the product, and must be signed by you or by one of your responsible employees.

There are third party testing services available that will test an organization’s products for levels of the restricted materials.

RoHS testing

All EEE should undergo laboratory testing to document compliance. The test report can demonstrate that your product complies with RoHS regulations.

Third party RoHS testing from HQTS enables you to ensure compliance to the relevant EU RoHS directive.  HQTS world-class testing facility ensures that your products are always within the acceptable range of compliance before they are sent to the European Union.

Similar regulations exist in other areas of the world including China, Japan, South Korea, USA, Norway and Turkey. Backed by the industry knowledge and experience of nearly 1,500 professionals in more than 20 countries, HQTS is well-suited to be your partner in quality.

About HQTS

HQTS offers expert guidance in conforming to industry, regulatory, and a customer’s exacting standards, as well as compliance with USA, European and international directives, standards, and testing requirements. We test per AATCC, ASTM, REACH, RoHS, ISO, SATRA, GB, and other related standards. Contact us today to find out how we can help you navigate current quality control challenges.








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