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- RoHS 2011/65/EU: 10 substances, exemptions, 2026 dates
RoHS 2011/65/EU: 10 substances, exemptions, 2026 dates
Directive 2011/65/EU (RoHS) restricts ten substances in electrical and electronic equipment placed on the EU market: lead, mercury, hexavalent chromium, PBB, PBDE and four phthalates at 0.1% by weight in each homogeneous material, and cadmium at 0.01%. The text has been amended dozens of times by delegated directives; the consolidated version used here is the one of 1 July 2026. Three things changed recently. In 2025 the Commission split the main lead exemptions (high-melting solders, lead in glass and ceramics, lead in steel, aluminium and copper) into narrower entries that apply from 1 July 2026 and expire between December 2026 and December 2027. Directive (EU) 2025/2456 moves exemption and restriction assessments to the European Chemicals Agency from 13 August 2027. And the 2023 review closed the door on a general recast for now. This guide sets out the substances, the scope dates per category, the exemption rules and the dated list of expiries, the IEC standards used for the file and the tests, and the misreadings that circulate about all of them.
TL;DR:
- 10 substances: Pb, Hg, Cr VI, PBB, PBDE, DEHP, BBP, DBP, DIBP at 0.1%; Cd at 0.01%; always per homogeneous material (Article 4(2), Annex II).
- Every product category is now in scope: category 11 ("other EEE") since 22 July 2019 (Article 4(3)).
- Exemptions last up to 5 years (up to 7 for categories 8 and 9) and stay valid while a renewal filed 18 months ahead is pending (Article 5(2) and 5(5)).
- Lead exemptions 6(a) to 6(c), 7(a) and 7(c) were rewritten in 2025: check your BOM against the new sub-entries before 30 June 2027.
- Conformity: module A, EU declaration of conformity, CE marking, file kept 10 years; harmonised standard EN IEC 63000:2018.
From RoHS 1 to RoHS 2
Section titled “From RoHS 1 to RoHS 2”Directive 2002/95/EC, the first RoHS directive, was adopted alongside the WEEE Directive 2002/96/EC and restricted six substances (Pb, Hg, Cd, Cr VI, PBB, PBDE). Directive 2011/65/EU is its recast: Member States had to transpose it by 2 January 2013 (Article 25) and Directive 2002/95/EC was repealed with effect from 3 January 2013 (Article 26).
The recast changed the nature of the regime more than the list of substances. It aligned RoHS with the New Legislative Framework: manufacturers carry out module A internal production control of Decision 768/2008/EC, draw up an EU declaration of conformity and affix the CE marking (Article 7). It spelt out obligations for authorised representatives, importers and distributors (Articles 8 to 10). It extended scope in stages to medical devices, monitoring and control instruments and, through category 11, to all other EEE (Article 4(3)). And it set a procedure to grant, renew and revoke exemptions by delegated act, with fixed maximum durations (Article 5).
The EMC, Low Voltage and Radio Equipment directives apply alongside RoHS; for how they combine under the CE marking, see the CE marking guide and the CE scope page.
Scope: the eleven categories and their start dates
Section titled “Scope: the eleven categories and their start dates”Annex I lists eleven categories. The restriction in Article 4(1) did not start on the same day for all of them: Article 4(3), as amended by Directive (EU) 2017/2102, gives the dates.
| Category (Annex I) | Restriction of the six original substances applies to EEE placed on the market from | Four phthalates from |
|---|---|---|
| 1 to 7 and 10 (household appliances, IT and telecom, consumer, lighting, tools, toys and leisure, automatic dispensers) | Already restricted under RoHS 1 (the Article 4(4) spare-part cut-off is 1 July 2006) | 22 July 2019 |
| 8, medical devices | 22 July 2014 | 22 July 2021 |
| 8, in vitro diagnostic medical devices | 22 July 2016 | 22 July 2021 |
| 9, monitoring and control instruments | 22 July 2014 | 22 July 2021 |
| 9, industrial monitoring and control instruments | 22 July 2017 | 22 July 2021 |
| 11, other EEE not covered by any category above | 22 July 2019 | 22 July 2019 |
"EEE" is defined in Article 3(1): equipment dependent on electric currents or electromagnetic fields to work properly, designed for a voltage rating not exceeding 1 000 V AC and 1 500 V DC. "Dependent" means needing current or fields for at least one intended function (Article 3(2)), which is why a product with a single electrical feature is in scope.
Article 2(4) excludes, among others: equipment for the essential security interests of Member States, including arms and war material; equipment designed to be sent into space; equipment specifically designed to be installed in excluded equipment; large-scale stationary industrial tools; large-scale fixed installations; means of transport for persons or goods, except electric two-wheel vehicles that are not type-approved; non-road mobile machinery made available exclusively for professional use; active implantable medical devices; photovoltaic panels installed by professionals for permanent use at a defined location; equipment designed solely for research and development and made available business-to-business only; and pipe organs, added by Directive 2017/2102.
The ten restricted substances (Annex II)
Section titled “The ten restricted substances (Annex II)”Annex II, in the version substituted by Delegated Directive (EU) 2015/863, sets the maximum concentration values tolerated by weight in homogeneous materials.
| Substance | Maximum concentration | Notes from the text |
|---|---|---|
| Lead (Pb) | 0.1% | Most exemptions in Annex III concern lead |
| Mercury (Hg) | 0.1% | Lamp exemptions are expressed in mg per lamp or burner |
| Cadmium (Cd) | 0.01% | The only substance at 0.01% |
| Hexavalent chromium (Cr VI) | 0.1% | Trivalent chromium is not listed |
| Polybrominated biphenyls (PBB) | 0.1% | |
| Polybrominated diphenyl ethers (PBDE) | 0.1% | |
| Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% | Added by 2015/863 |
| Butyl benzyl phthalate (BBP) | 0.1% | Added by 2015/863 |
| Dibutyl phthalate (DBP) | 0.1% | Added by 2015/863 |
| Diisobutyl phthalate (DIBP) | 0.1% | Added by 2015/863 |
Directive 2015/863 had to be transposed by 31 December 2016 and applied from 22 July 2019 (its Article 2). Annex II adds three phthalate-specific rules: the restriction applies to medical devices (including in vitro diagnostic devices) and monitoring and control instruments (including industrial ones) from 22 July 2021; it does not apply to cables or spare parts for EEE placed on the market before 22 July 2019, or before 22 July 2021 for those medical and instrument categories; and DEHP, BBP and DBP do not apply to toys already restricted for those substances by entry 51 of REACH Annex XVII.
The homogeneous material rule
Section titled “The homogeneous material rule”Article 4(2) tolerates "no more than the maximum concentration value by weight in homogeneous materials", and Article 3(20) defines a homogeneous material as "one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes".
In practice the solder alloy of a joint, the plating on a lead frame, the mould compound of a package, the insulation and the jacket of a cable, or the zinc coating and the passivation on a screw are each assessed separately. Averaging a concentration over a component, a board or a finished product is not what the text measures, and a whole-product analysis can dilute a local excess below the threshold. That is why RoHS evidence is built bottom-up from supplier data per material and targeted tests on the materials most likely to contain a restricted substance.
How exemptions work (Article 5)
Section titled “How exemptions work (Article 5)”Article 4(6) disapplies the restriction for the applications listed in Annex III (all categories, unless an entry says otherwise) and Annex IV (specific to categories 8 and 9). The procedural rules are in Article 5 and Annex V.
| Rule | What the text says | Where |
|---|---|---|
| Grounds | Substitution scientifically or technically impracticable, reliability of substitutes not ensured, or substitution impacts likely to outweigh benefits; and no weakening of REACH protection | Article 5(1)(a) |
| Maximum validity, new or renewed exemptions | Up to 5 years for categories 1 to 7, 10 and 11; up to 7 years for categories 8 and 9; renewable | Article 5(2), first subparagraph |
| Annex III entries existing on 21 July 2011 | 5 years from 21 July 2011 (categories 1 to 7, 10); 7 years from the Article 4(3) dates (categories 8, 9); 5 years from 22 July 2019 (category 11) | Article 5(2), second subparagraph |
| Who can apply | A manufacturer, its authorised representative or any economic operator in the supply chain | Annex V |
| Renewal deadline | At least 18 months before expiry; the exemption remains valid until the Commission decides | Article 5(5) |
| Rejection or revocation | The exemption expires at the earliest 12 months and at the latest 18 months after the decision | Article 5(6) |
| Cables and spare parts | Products placed on the market under an exemption may still be repaired with parts that rely on it | Article 4(4)(f) |
Article 5(5) explains a reading trap. Many Annex III entries still print expiry dates of 21 July 2021, 21 July 2023 or 21 July 2024. Where renewal applications were filed in time, those exemptions stayed valid until the Commission decided. The recitals of Delegated Directives 2025/1802, 2025/2363 and 2025/2364 say so explicitly for entries 7(a), 7(c)-I, 7(c)-II and 6(a) to 6(c). A past date in the annex is therefore a prompt to check whether a renewal is pending, not proof that the exemption has lapsed, and the reverse is also true: once the Commission decides, the new dates bind.
The 2025 rewrite of the lead exemptions
Section titled “The 2025 rewrite of the lead exemptions”Three delegated directives signed on 8 September 2025 and published in the Official Journal on 21 November 2025 entered into force on 11 December 2025. Member States had to transpose them by 30 June 2026 and apply them from 1 July 2026. They replace broad entries with application-specific sub-entries.
| Entry | Content after 2025 | Expiry |
|---|---|---|
| 7(a) | Lead in high melting temperature type solders (lead-based alloys with 85% by weight or more lead), general entry | 30 June 2027 |
| 7(a)-I to 7(a)-VII | Same solders, limited to: die attach in semiconductor assemblies above set current, voltage or die-size thresholds (I); die attach with conductivity and solidus conditions (II); first level solder joints (III); ceramic BGA balls and high-temperature overmouldings (IV); hermetic sealing (V); lamp component connections (VI); audio transducers above 200 °C (VII) | 31 December 2027 |
| 7(c)-I | Lead in glass or ceramic other than dielectric ceramic in capacitors | 30 June 2027 |
| 7(c)-II | Lead in dielectric ceramic in capacitors rated 125 V AC or 250 V DC or higher | 31 December 2027 |
| 7(c)-V (new) | Lead in glass for diode glass beads and wafer layers, hermetic seals, low-temperature bonding, resistive inks, microchannel plates and similar | 31 December 2027 |
| 7(c)-VI (new) | Lead in PZT piezoelectric ceramics and PTC ceramics | 31 December 2027 |
| 6(a) | Lead in machining steel and galvanised steel up to 0.35% | 11 December 2026 |
| 6(a)-I, 6(a)-II | Machining steel up to 0.35% lead; batch hot-dip galvanised steel up to 0.2% lead | 30 June 2027, all categories |
| 6(b) | Lead in aluminium up to 0.4% | 11 June 2027 |
| 6(b)-I | Aluminium up to 0.4% lead from recycled lead-bearing scrap | 11 December 2026 (categories 1 to 7, 10); 30 June 2027 (industrial instruments, category 11) |
| 6(b)-II | Machining aluminium up to 0.4% lead | 11 June 2027 (categories 1 to 7, 10); 30 June 2027 (industrial instruments, category 11) |
| 6(b)-III (new) | Aluminium casting alloys up to 0.3% lead from recycled scrap | 30 June 2027 (categories 1 to 8, 9 other than industrial, 10) |
| 6(c) | Copper alloy up to 4% lead | 30 June 2027 |
Entries 6(a)-I to 6(c) now carry a footnote: they do not cover EEE supplied to the general public whose accessible parts smaller than 5 cm in one dimension may be placed in the mouth by children, unless lead release stays at or below 0.05 µg/cm² per hour (and, for coated parts, for at least two years of use).
The pattern is the same across all three acts: the general entry gets a short phase-out date, and only applications that fit a named sub-entry continue to 31 December 2027 or 30 June 2027. A BOM line that relied on "7(a)" or "6(c)" in general must now be mapped to a sub-entry, or redesigned.
Other exemption dates to watch, 2026 to 2028
Section titled “Other exemption dates to watch, 2026 to 2028”From the consolidated text of 1 July 2026 (dates as printed; a renewal filed in time keeps an entry valid beyond its date).
| Annex and entry | Application | Printed expiry |
|---|---|---|
| III, 45 | Lead compounds in electric and electronic initiators of explosives for civil use, and barium chromate in pyrotechnic delay charges (category 11) | 20 April 2026 |
| IV, 42 | Mercury in rotating connectors of intravascular ultrasound imaging systems above 50 MHz | 30 June 2026 |
| III, 9(a)-III | Up to 0.7% Cr VI as anti-corrosion agent in gas absorption heat pumps (category 1), granted by 2023/171 | 31 December 2026 |
| III, 1(f)-I, 2(b)(4)-II, 2(b)(4)-III, 4(a)-I, 4(e), 4(f)-II to 4(f)-IV | Mercury in UV lamps, emergency lamps, metal halide lamps, projector and horticulture lamps | 24 February 2027 |
| IV, 44 | Cadmium in radiation tolerant video camera tubes (category 9) | 31 March 2027 |
| III, 39(b) | Cadmium in quantum dots deposited on LED chips, granted by 2024/1416 | 31 December 2027 |
| III, 46 | Cadmium and lead in recovered rigid PVC profiles of electrical windows and doors (category 11), granted by 2024/232 | 28 May 2028 |
| IV, 45 and 47 | DEHP in ion-selective electrodes; four phthalates in spare parts recovered for medical device repair | 21 July 2028 |
Entry 39(a), cadmium selenide quantum dots for display lighting, expired for all categories on 21 November 2025.
What is changing: ECHA from 13 August 2027, and no general recast
Section titled “What is changing: ECHA from 13 August 2027, and no general recast”| Item | Status on 7 October 2026 | Source |
|---|---|---|
| General review under Article 24(2) | Report COM(2023) 760 of 7 December 2023: no general revision "at this stage", a targeted amendment instead; a future revision should review scope (photovoltaic panels named), drop obsolete transitional provisions and clean expired exemptions from the annexes | COM(2023) 760 |
| Directive (EU) 2025/2456 | Adopted 26 November 2025, in force 1 January 2026, applies from 13 August 2027. Exemption applications go to ECHA, whose Committee for Socio-economic Analysis (and Committee for Risk Assessment for new exemptions) gives opinions; ECHA prepares restriction dossiers; Annex II must be reviewed at least every 4 years | Directive (EU) 2025/2456 |
| Adding TBBP-A and medium-chain chlorinated paraffins to Annex II | Initiative Ares(2022)3631399, recommended by a technical assessment, marked abandoned on 10 December 2024 | Have your say 13469 |
| Lead and cadmium exemptions (fluorescent tube glass, laser tubes and others) | Draft delegated directive Ares(2026)6840617 published 8 July 2026, feedback closed 5 August 2026, adoption pending | Have your say 14509 |
Technical documentation and EN IEC 63000
Section titled “Technical documentation and EN IEC 63000”Article 7 makes the manufacturer draw up the technical documentation, run module A internal production control, issue the EU declaration of conformity, affix the CE marking and keep the documentation and the declaration for 10 years after placing on the market. Importers keep a copy of the declaration for 10 years and must be able to supply the documentation on request (Article 9(g)). The declaration follows the model in Annex VI: it states conformity with Directive 2011/65/EU and lists, where applicable, the harmonised standards or technical specifications used. Where other Union legislation requires a procedure at least as stringent, RoHS compliance can be demonstrated within it and a single technical documentation can be drawn up (Article 7(c)).
Article 16(2) gives presumption of conformity to assessments made under harmonised standards cited in the Official Journal. Implementing Decision (EU) 2020/659 cited EN IEC 63000:2018 ("Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances") and withdrew EN 50581:2012 from 18 November 2021. EN IEC 63000:2018 is the European adoption of IEC 63000:2016; the IEC has since published amendment 1 (consolidated as IEC 63000:2016+AMD1:2022). The approach is risk-based: the manufacturer assesses how likely restricted substances are in each material, part or sub-assembly and how trustworthy each supplier is, collects supplier declarations, material declarations or analytical results accordingly, and reviews them.
Test methods: the IEC 62321 series
Section titled “Test methods: the IEC 62321 series”EN IEC 63000 covers the file; laboratory determinations use the IEC 62321 series, and the part depends on the substance and on the matrix. X-ray fluorescence screening measures elements, so it cannot by itself separate Cr VI from Cr III or identify phthalates.
- IEC 62321-7-1:2015: boiling-water extraction giving a qualitative result (positive, negative or inconclusive) for Cr(VI) in colourless and coloured corrosion-protection coatings on metals. A plated screw comes back as a presence result, not as a concentration.
- IEC 62321-7-2:2017: quantitative determination of Cr(VI) in polymers and electronics, by solvent swelling and alkaline digestion followed by colorimetry.
- IEC 62321-8:2017: phthalates (DIBP, DBP, BBP, DEHP and others) in polymers by GC-MS and by GC-MS with a pyrolyser or thermal-desorption accessory (Py-TD-GC-MS).
Ordering "62321-7" without saying which part sends the wrong method to the wrong parts. See the CE technical file guide for how the RoHS evidence sits in the overall CE file. AESTECHNO does not perform chemical laboratory analysis; that work goes to an ISO/IEC 17025 accredited laboratory.
Market surveillance
Section titled “Market surveillance”Article 16(1) presumes EEE bearing the CE marking to comply unless there is evidence to the contrary. Directive 2011/65/EU is one of the acts listed in Article 4(5) of Regulation (EU) 2019/1020: a product covered by it can only be placed on the EU market if an economic operator established in the Union (manufacturer, importer, authorised representative or fulfilment service provider) is responsible for the tasks in that article and is named on the product, its packaging, the parcel or an accompanying document. Penalties for improper use of the CE marking are set by Member States, and may include criminal sanctions for serious infringements (Article 15(3)).
For the RoHS calendar against other regimes (REACH, batteries, CRA, ESPR), see the certification timeline guide. The wider chemicals regime is in the REACH and SVHC guide.
RoHS-type regimes outside the EU
Section titled “RoHS-type regimes outside the EU”These regimes copy the idea, not the text. A CE/RoHS file is a starting point, never a substitute.
| Jurisdiction | Text | Substances | What differs |
|---|---|---|---|
| China | Management methods for restricting hazardous substances in electrical and electronic products, Order No. 32 of MIIT and seven other authorities, in force 1 July 2016 | Pb, Hg, Cd, Cr VI, PBB, PBDE and others the State specifies | Every producer and importer marks substance names, content and location and an environment-friendly use period (Articles 13 and 14); limits are enforced, with a conformity assessment system, only for products in a published compliance catalogue (Articles 17 and 18) |
| India | E-Waste (Management) Rules, 2022, rule 16 | Pb, Hg, Cr VI, PBB, PBDE at 0.1%, Cd at 0.01%, per homogeneous material | Applies to EEE listed in Schedule I; no phthalates; dated carve-outs for parts and for Schedule II C equipment |
| United Kingdom | The RoHS Regulations 2012 (SI 2012/3032) | Set by the UK regulations | Separate UK legislation; see UKCA marking for the marking regime |
For other jurisdictions, check the national text before reusing an EU file; CE vs FCC for EMC explains the broader regional split. The glossary covers the key terms.
Claims the texts contradict
Section titled “Claims the texts contradict”| Common claim (including on earlier versions of this page) | What the text says |
|---|---|
| "Lead in high-temperature solders" means solders melting above some fraction of the reflow window | Entry 7(a) is defined by composition: lead-based alloys containing 85% by weight or more lead. Since 2025 most uses must fit sub-entries 7(a)-I to VII (Delegated Directive 2025/1802) |
| An exemption whose printed date has passed is dead | Article 5(5): a renewal filed at least 18 months before expiry keeps it valid until the Commission decides; the 2025 acts cite exactly this for 7(a), 7(c) and 6(a) to 6(c) |
| Exemption renewals are filed by industry consortia or associations | Annex V: a manufacturer, an authorised representative or any economic operator in the supply chain may apply. From 13 August 2027 the application goes to ECHA, not the Commission |
| The phthalates apply from 2019 to categories 1 to 7 and 10 only | 2015/863 applied from 22 July 2019 to all EEE, category 11 included; only medical devices and monitoring and control instruments were deferred to 22 July 2021 |
| Directive 2017/2102 is a Commission delegated directive | It is a Directive of the European Parliament and of the Council, transposition by 12 June 2019. It deleted Article 2(2), excluded pipe organs, redefined non-road mobile machinery and allowed reused spare parts in closed-loop business-to-business systems (Article 4(5)) |
| RoHS 2 lets any spare part for pre-2011 equipment escape RoHS if it is "equivalent" | Article 4(4) exempts cables and spare parts by cut-off date per category (1 July 2006 for the original scope, 22 July 2014, 2016, 2017 or 2019 for the rest), and Article 4(5) covers reused parts only in auditable closed-loop B2B systems with notice to the consumer |
| Vehicles are excluded as "categories M, N, L" | Article 2(4)(f) excludes means of transport for persons or goods, except electric two-wheel vehicles that are not type-approved |
| Cadmium is exempt in circuit-breaker contacts | Entry 8(b)-I (circuit breakers, thermal controls, certain switches) applied to categories 1 to 7 and 10 and expired on 21 July 2021; 8(b) for categories 8, 9 and 11 carries 2021 to 2024 dates subject to Article 5(5) |
| The harmonised standard is "IEC 63000:2018" | The cited standard is EN IEC 63000:2018, which adopts IEC 63000:2016 (Implementing Decision 2020/659) |
| India restricts the six RoHS substances plus the four phthalates | Rule 16 of the E-Waste (Management) Rules 2022 lists six substances (Pb, Hg, Cd, Cr VI, PBB, PBDE) |
| A RoHS revision adding new substances is under way | COM(2023) 760 ruled out a general revision for now, and the TBBP-A and medium-chain chlorinated paraffins initiative is marked abandoned (10 December 2024). The live change is the transfer of tasks to ECHA from 13 August 2027 |
Watch-out points
Section titled “Watch-out points”| Risk | Consequence | Action |
|---|---|---|
| Limits applied per component or per product | Local exceedances hidden by dilution | Collect data and test per homogeneous material |
| BOM still cites 7(a), 7(c)-I or 6(c) in general | The general entries expire on 30 June 2027 (6(a): 11 December 2026) | Map each use to a 2025 sub-entry or plan substitution |
| Category 11 product treated as out of scope | All ten substances apply since 22 July 2019 | Check the Article 2(4) exclusions one by one before relying on them |
| Cr VI and Cr III confused on coatings | Wrong acceptance or rejection of passivations | Use IEC 62321-7-1 for coatings on metal, 7-2 for polymers and electronics |
| Exemption register not maintained | A refused renewal ends the exemption 12 to 18 months after the decision | Track pending renewals and the ECHA procedure from August 2027 |
| EU file reused unchanged in China or India | Different scope, marking and substance lists | Map the file to each national text |
See also
Section titled “See also”- Environmental compliance: what it asks of a product
- CPSIA and ASTM F963: toy safety in the United States
- REACH 1907/2006: chemical substances and SVHC
- WEEE 2012/19/EU: European e-waste management framework
- DEEE in France: French version of EU WEEE
- EU Battery Regulation 2023/1542: passport, carbon
- EU declaration of conformity
- Technical documentation file contents
Sources & references
- Directive 2011/65/EU (RoHS), consolidated text of 1 July 2026, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02011L0065-20260701
- Directive 2011/65/EU, original Official Journal text, EUR-Lex eur-lex.europa.eu/eli/dir/2011/65/oj
- Commission Delegated Directive (EU) 2015/863 (four phthalates added to Annex II), EUR-Lex eur-lex.europa.eu/eli/dir_del/2015/863/oj
- Directive (EU) 2017/2102 amending Directive 2011/65/EU (scope, spare parts, category 11), EUR-Lex eur-lex.europa.eu/eli/dir/2017/2102/oj
- Commission Delegated Directive (EU) 2025/1802 (lead in high melting temperature solders, entry 7(a)), EUR-Lex eur-lex.europa.eu/eli/dir_del/2025/1802/oj
- Commission Delegated Directive (EU) 2025/2363 (lead in glass or ceramic components, entries 7(c)), EUR-Lex eur-lex.europa.eu/eli/dir_del/2025/2363/oj
- Commission Delegated Directive (EU) 2025/2364 (lead in steel, aluminium and copper, entries 6(a) to 6(c)), EUR-Lex eur-lex.europa.eu/eli/dir_del/2025/2364/oj
- Commission Delegated Directive (EU) 2024/1416 (cadmium in quantum dots on LED chips, entry 39(b)), EUR-Lex eur-lex.europa.eu/eli/dir_del/2024/1416/oj
- Directive (EU) 2025/2456 (transfer of RoHS scientific and technical tasks to ECHA), EUR-Lex eur-lex.europa.eu/eli/dir/2025/2456/oj
- Commission Implementing Decision (EU) 2020/659 (EN IEC 63000:2018 cited, EN 50581:2012 withdrawn), EUR-Lex eur-lex.europa.eu/eli/dec_impl/2020/659/oj
- COM(2023) 760, Commission report on the review of the RoHS Directive, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023DC0760
- Have your say: lead and cadmium in certain electric and electronic components (RoHS exemption), draft act Ares(2026)6840617, European Commission ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14509_en
- Have your say: amending the list of restricted substances (TBBP-A, medium-chain chlorinated paraffins), initiative abandoned, European Commission ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13469_en
- European Commission, RoHS Directive page, European Commission environment.ec.europa.eu/topics/waste-and-recycling/rohs-directive_en
- IEC 63000:2016+AMD1:2022 CSV, technical documentation for RoHS assessment, IEC webstore.iec.ch/en/publication/73587
- IEC 62321-7-1:2015, Cr(VI) in corrosion-protection coatings on metals (qualitative), IEC webstore.iec.ch/en/publication/23320
- IEC 62321-7-2:2017, Cr(VI) in polymers and electronics (quantitative), IEC webstore.iec.ch/en/publication/28107
- IEC 62321-8:2017, phthalates in polymers by GC-MS and Py-TD-GC-MS, IEC webstore.iec.ch/en/publication/32719
- Regulation (EU) 2019/1020 on market surveillance (Article 4 covers RoHS products), EUR-Lex eur-lex.europa.eu/eli/reg/2019/1020/oj
- China, MIIT and seven ministries Order No. 32 (2016), management methods for restricting hazardous substances in EEP, State Council of the People's Republic of China www.gov.cn/gongbao/content/2016/content_5065677.htm
- India, CPCB FAQs under the E-Waste (Management) Rules, 2022 (rule 16 RoHS provisions), Central Pollution Control Board cpcb.nic.in/uploads/Projects/E-Waste/FAQ_ewaste_23012024.pdf
- UK, The RoHS Regulations 2012 (SI 2012/3032), legislation.gov.uk www.legislation.gov.uk/uksi/2012/3032/contents
Frequently asked questions
- What is the difference between RoHS 1 and RoHS 2?
- Directive 2002/95/EC (RoHS 1) restricted six substances and was repealed with effect from 3 January 2013 by Directive 2011/65/EU (RoHS 2), a recast that Member States had to transpose by 2 January 2013. RoHS 2 added New Legislative Framework mechanics: module A internal production control, an EU declaration of conformity, CE marking and obligations for manufacturers, authorised representatives, importers and distributors. It also brought medical devices and monitoring and control instruments into scope in stages (2014, 2016, 2017) and, through category 11, all other EEE from 22 July 2019.
- What are the ten restricted substances and their limits?
- Annex II, as replaced by Delegated Directive (EU) 2015/863, lists lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP at 0.1 percent by weight in homogeneous materials, and cadmium at 0.01 percent. The four phthalates apply from 22 July 2019, and from 22 July 2021 for medical devices (including in vitro diagnostic devices) and monitoring and control instruments.
- Do the phthalate restrictions apply to category 11 products?
- Yes. Directive 2015/863 had to be applied from 22 July 2019, the same day category 11 EEE came into scope under Article 4(3). Annex II only defers the four phthalates for medical devices and monitoring and control instruments, to 22 July 2021. Cables and spare parts for EEE placed on the market before those dates are exempt from the phthalate restriction, and DEHP, BBP and DBP do not apply to toys already covered by REACH Annex XVII entry 51.
- What is a homogeneous material?
- Article 3(20) defines it as one material of uniform composition throughout, or a material made of a combination of materials that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. Article 4(2) applies the maximum concentration values to each homogeneous material, so a solder joint, a plating layer or a cable insulation is assessed on its own, not averaged over the component or the product.
- How long do Annex III and Annex IV exemptions last?
- Under Article 5(2), up to 5 years for categories 1 to 7, 10 and 11 and up to 7 years for categories 8 and 9, decided case by case and renewable. A renewal application must be filed at least 18 months before expiry, and the exemption then stays valid until the Commission decides. If renewal is refused, the exemption ends 12 to 18 months after the decision. That is why many entries still show 2021, 2023 or 2024 dates while remaining usable.
- Which exemptions changed in 2025 and 2026?
- Delegated Directives (EU) 2025/1802, 2025/2363 and 2025/2364, in force since 11 December 2025 and applicable from 1 July 2026, split the lead entries 7(a) (high-melting solders), 7(c)-I and 7(c)-II (lead in glass and ceramic) and 6(a) to 6(c) (lead in steel, aluminium and copper) into narrower sub-entries. Most sub-entries expire on 30 June 2027 or 31 December 2027, and 6(a) expires on 11 December 2026.
- Which standard gives presumption of conformity for RoHS?
- EN IEC 63000:2018, cited by Implementing Decision (EU) 2020/659, which withdrew EN 50581:2012 from 18 November 2021. EN IEC 63000:2018 adopts the international standard IEC 63000:2016. It covers the technical documentation, not test methods: laboratory measurements use the IEC 62321 series.
- Is RoHS being revised?
- Not as a general recast. The 2023 Commission review report (COM(2023) 760) chose a targeted amendment instead, adopted as Directive (EU) 2025/2456: from 13 August 2027, exemption applications go to the European Chemicals Agency (ECHA), which also prepares restriction dossiers. The initiative to add TBBP-A and medium-chain chlorinated paraffins to Annex II is marked abandoned (10 December 2024). A further draft delegated directive on lead and cadmium exemptions was open for feedback from 8 July to 5 August 2026.