Restricted Substances, Exemptions, and Global RoHS-Style Regulations
Officially titled the Restriction of Hazardous Substances, RoHS is a directive enacted by the European Union (EU) to restrict the use of harmful and dangerous substances in electrical and electronic equipment (EEE). While RoHS technically entered into force in 2003, EU nations had until July 1, 2006 to fully comply with the regulation. From that point forward, RoHS restricted the use of six specific substances in EEE: Cadmium (Cd), Mercury (Hg), Lead (Pb), Hexavalent chromium (Cr6+), Polybrominated biphenyls (PBB), and Polybrominated diphenyl ethers (PBDE). Since the directive was first adopted over two decades ago, the EU has expanded its scope on several occasions. In 2011, Directive 2011/65/EU (often referred to as "RoHS 2") increased the number of products within the remit of the regulation while also introducing new obligations on EEE manufacturers. In 2015, Directive 2015/863, or "RoHS 3," was passed, restricting four additional substances in EEE manufacturing: Bis(2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP), and Diisobutyl phthalate (DIBP).
RoHS restricts ten hazardous substances in electrical and electronic equipment. The original six were restricted from the 2006 compliance deadline, and four phthalates were added under RoHS 3 (Directive 2015/863) in 2015. The table below lists each substance, its common abbreviation, and the directive that brought it into scope.
The 10 RoHS Restricted Substances
| Substance | Abbreviation | When Restricted |
|---|---|---|
| Cadmium | Cd | Original 6, restricted from 2006 |
| Mercury | Hg | Original 6, restricted from 2006 |
| Lead | Pb | Original 6, restricted from 2006 |
| Hexavalent chromium | Cr6+ | Original 6, restricted from 2006 |
| Polybrominated biphenyls | PBB | Original 6, restricted from 2006 |
| Polybrominated diphenyl ethers | PBDE | Original 6, restricted from 2006 |
| Bis(2-ethylhexyl) phthalate | DEHP | Added under RoHS 3 (Directive 2015/863), 2015 |
| Butyl benzyl phthalate | BBP | Added under RoHS 3 (Directive 2015/863), 2015 |
| Dibutyl phthalate | DBP | Added under RoHS 3 (Directive 2015/863), 2015 |
| Diisobutyl phthalate | DIBP | Added under RoHS 3 (Directive 2015/863), 2015 |
Though RoHS is broadly focused on electrical and electronic equipment, an effective regulation relies on a precise, sharply delineated scope regarding covered products. To that end, the directive has established 11 product categories impacted by RoHS. While these categories all encompass products that use electronic components like transistors, diodes, and semiconductors to manipulate the flow of an electric current (thereby fulfilling the most fundamental definition of "electronics"), they also stretch across a slew of different industries and manufacturing fields.
Certain categories are exempt from the restrictions imposed by RoHS. While the specific reasoning may vary from one product to the next, these goods are generally excluded because of their vital importance to critical concerns like national defense, scientific research and development, and human health. In some cases, the near-term costs associated with reformulating these products to adhere to RoHS may outweigh the long-term benefits.
Manufacturers, importers, and other suppliers of EEE in the European Union may choose to use an independent third party to ensure that they are fully compliant with RoHS. These organizations, also known as conformity assessment bodies (CABs), carry out a number of steps to obtain all the information necessary to comprehensively evaluate the compliance of their clients. To issue a RoHS certification, a conformity assessment body needs to conduct chemical testing on the products in question to determine whether restricted substances are present above the EU's legal thresholds. In addition, these organizations typically investigate manufacturing processes, generally on-site; review all applicable documentation, including bills of materials (BOMs) and full material declarations (FMDs); and evaluate a technical file that encompasses product design structure, risk assessments, and manufacturing records.
Since RoHS was initially introduced in 2006, the EU environmental directive has served as something of a trailblazer for other laws regulating EEE around the globe. Many of the largest nations and economies in the world now have regulations in place that draw from the RoHS framework in an effort to mitigate the negative impact of the hazardous substances used in electronics. The table below highlights several of the most significant RoHS-style regulations. While the United States does not have a RoHS equivalent at the federal level, a number of states have adopted and implemented regulations limiting concentrations of specific heavy metals and other substances in electronics.
Selected RoHS-Style Regulations Around the World
| Jurisdiction | Regulation | Notes |
|---|---|---|
| European Union | RoHS (Directive 2011/65/EU) | The original directive restricting hazardous substances in EEE; baseline for regulations worldwide |
| China | China RoHS | Administrative Measure on the Control of Pollution Caused by Electronic Information Products, maintained by MIIT |
| United Kingdom | UK RoHS | UK's post-Brexit equivalent restricting hazardous substances in electrical and electronic equipment |
| India | E-Waste Management Rules | Restricts hazardous substances in electronics alongside e-waste handling requirements |
| Japan | J-MOSS | Japanese Industrial Standard for the Marking of Specific Chemical Substances |
| United States | State-level laws | No federal RoHS equivalent; individual states limit concentrations of specific heavy metals and other substances |
While dozens of countries around the world adhere to the original EU RoHS or a similar chemical regulation, the size and influence of China on worldwide electronics manufacturing make its version of the directive uniquely important. The country's RoHS equivalent is officially known as the Administrative Measure on the Control of Pollution Caused by Electronic Information Products, and the regulation is published and maintained by the Ministry of Industry and Information Technology (MIIT). Since the regulation's inception in 2006, China RoHS has focused on the same six substances originally restricted by the EU's RoHS: Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent chromium (Cr6+), Polybrominated biphenyls (PBB), and Polybrominated diphenyl ethers (PBDE). In June 2024, MIIT passed an amendment that added the four chemicals the original RoHS began regulating in 2015 to its own list of restricted substances: bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP). Once these restrictions go into effect beginning on January 1, 2026, China RoHS will be in full alignment with its EU counterpart.
RoHS has grown steadily since it first entered into force, broadening its product scope, adding manufacturer obligations, and expanding its list of restricted substances. The timeline below traces the directive's major milestones and the convergence of China RoHS with the EU framework.
RoHS and the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) are both environmental regulations administered and enforced by the European Union. Conflating the two, using them interchangeably, or assuming significant overlap between the laws is a major misstep, because they differ significantly in both structure and scope. While RoHS is exclusively focused on restricting the use of 10 hazardous substances across a number of different EEE categories, REACH is a more complex regulation. The chemical directive requires manufacturers and other in-scope businesses that fall within the purview of REACH to register chemical substances with the European Chemicals Agency by submitting comprehensive dossiers. In addition, REACH maintains a list of substances considered to be of "very high concern" (known as the Candidate or SVHC List), and presides over an authorization process for organizations seeking to use specific banned substances.
In 2022, the European Commission submitted a proposal to add two new substances to the EU RoHS Annex II, which covers hazardous substances restricted by the directive: tetrabromobisphenol A (TBBPA), a flame retardant used in plastics and synthetic resins and found to be an endocrine system disruptor; and medium-chain chlorinated paraffins (MCCPs), a family of industrial chemicals believed to be persistent, bioaccumulative, and toxic (PBT). While the European Commission proposal, which would have expanded the list of substances restricted by RoHS to 12, was originally expected to be adopted by 2024, it remains on hold with no definitive timetable for passing or entering into force.
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