Restriction of Hazardous SubstancesRoHS

RoHS — the EU Directive on the Restriction of Hazardous Substances in electrical and electronic equipment, recast as 2011/65/EU and amended by 2015/863 — restricts the use of ten substances in the equipment placed on the EU market: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers, and the four phthalates DEHP, BBP, DBP, and DIBP. The restriction is by maximum concentration in the homogeneous material — 0.1 per cent for most, 0.01 per cent for cadmium — and the threshold is measured at the smallest indivisible unit of the product, not the average. The scope covers the product categories in Annex I, with exclusions in Annex III and exemptions in Annex IV that a manufacturer can claim for a specific technical use.

The compliance evidence is the EU Declaration of Conformity and the technical documentation the manufacturer maintains for ten years, and the CE mark on the product signals the conformity to RoHS alongside the other applicable directives. The relationship to REACH is the one that confuses most compliance teams: RoHS restricts substances in the electronic equipment; REACH restricts substances across all uses, and the SVHC disclosure under REACH applies to the same product alongside the RoHS restriction. The manufacturer that holds the Bill of Substances against both, with the supplier declarations cascaded down the chain, holds the evidence the market-surveillance authority asks for. See REACH and SDS.