RoHS Compliance Testing CertificationRoHS is short for “The Directive on the Restriction of the use of Certain Hazardous Substances in Electrical and Electronic Equipment”. The first version of RoHS Directive (2002/95/EC) was passed by the European Parliament on 27 January 2003; the European Union published the new version of RoHS Directive, RoHS 2 Directive (2011/65/EU), on 1 July 2011 and the new directive became effective on 21 July 2011, taking the place of the previous version.

Contents of RoHS

Annex I: Categories of EEE covered by this Directive

AnnexII: Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials

AnnexIII: Applications exempted from the restriction in Article 4(1)

AnnexIV: Applications exempted from the restriction in Article 4(1) specific to medical devices and monitoring and control instruments

AnnexV: Applications for granting, renewing and revoking exemptions as referred to in Article 5

AnnexVI: EU Declaration of Conformity

Core Requirements of RoHS

According to the requirement of RoHS 2 listed on Article 4, paragraph 1, Member States shall ensure that the electrical and electronic equipments (EEE) placed on the market, including cables and spare parts for its repair, its reuse, updating of its functionalities or upgrading of its capacity, does not contain the substances listed in Annex II. And substances restricted under RoHS 2.0 are listed as follows:

Substances Restricted under RoHS 2.0

SubstanceCAS NOLimit/ppmDate of applicabilityReferencesScope
Cadmium, Cd7439-97-61001-Jul-062002/95/EC1. Large household appliances.
2005/618/EC2. Small household appliances.
Mercury, Hg7439-92-110003. IT and telecommunications equipment.
Lead, Pb7440-43-910004. Consumer equipment.
Hexavalent chromium, Cr (VI)7440-47-310005. Lighting equipment.
Polybrominated biphenyls, PBBs59536-65-110006. Electrical and electronic tools.
Polybrominated diphenyl ethers, PBDEs39 mixtures10007. Toys, leisure and sports equipment.
Bis(2-ethylhexyl) phthalate, DEHP117-81-7100022 July 2019 (excluding medical devices, monitoring and control instruments);(EU) 2015/8638. Medical devices.
Butyl benzyl phthalate, BBP85-68-7100022 July 2021 ( for medical devices, monitoring and control instruments9. Monitoring and control instruments including industrial monitoring and control instruments.
Dibutyl phthalate, DBP84-74-2100010. Automatic dispensers.
Diisobutyl phthalate, DIBP84-69-5100011. Other EEE not covered by any of the categories above

Among the above substances, four phthalates (DEHP, BBP, DBP and DIBP) were officially included in the list of restricted substances (ANNEX II) under the amendment (EU) 2015/863 on 4 June 2015 (see our report on June 5, 2015- Four phthalates are included in the restricted substances of RoHS 2.0).

For the above restrictions, the implement time of different types of products are different:

  • Medical devices, monitoring and control instruments: applied from July 22, 2014;
  • Medical devices for external diagnosis: applied from July 22, 2016;
  • Industrial monitoring and control instruments: applied from July 22, 2017;
  • Other EEE not covered by any of the categories above: will be applied from July 22, 2019.

The Scope for RoHS

RoHS Directive of the European Union covers an extensive scope of products, including almost all of electronic and electrical equipment, medical devices, telecommunications equipment, toys and security information products. It not only includes finished products, but also spare parts, raw materials and packaging intended for the production of the finished products, thus closely associated with the entire production chain.

Categories of EEE covered by this DirectiveProducts that this Directive does not apply to
1. Large household appliances.
2. Small household appliances.
3. IT and telecommunications equipment.
4. Consumer equipment.
5. Lighting equipment.
6. Electrical and electronic tools.
7. Toys, leisure and sports equipment.
8. Medical devices.
9. Monitoring and control instruments.
10. Automatic dispensers.
11. Other EEE not covered by any of the categories above.
(a) equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes;
(b) equipment designed to be sent into space;
(c) equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded or does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment, and which can be replaced only by the same specifically designed equipment;
(d) large-scale stationary industrial tools;
(e) large-scale fixed installations;
(f) means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved;
(g) non-road mobile machinery made available exclusively for professional use;
(h) active implantable medical devices;
(i) photovoltaic panels intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications;
(j) equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis.

Exemption of RoHS

In addition to products that RoHS Directive does not apply to, there are some products that meet the definition of RoHS Directive, but they can’t avoid their excessive use of hazardous substances due to the reason that the existing technical means cannot find more appropriate substitutes or their substitutes are so expensive that they do not meet the demands of current social and economic benefit. In regard to these specific purposes, RoHS Directive grants exemptions in Annex III and Annex IV, stipulating that if the product meets several certain rules, it can be launched on the EU market even if their material does not meet the limitation of quantity under RoHS Directive.

Annex III: Applications exempted from the restriction in Article 4(1)

Annex IV: Applications exempted from the restriction in Article 4(1) specific to medical devices and monitoring and control instruments

It should be noted that the exemption is not valid all the time, and every clause of the RoHS exemption has a period of validity. So companies should keep paying attention to the latest news of RoHS exemption and replace the voided exempted materials in their products. Maximum validity period of exemptions under RoHS 2 as of 21 July 2011 are listed as follows:

Category Annex IMaximum validity period for new exemptionsValidity period for existing exemptions where no expiry date is specifiedValidity period for existing exemptions where an expiry date is specified
1-7, 10 (not applicable to Annex IV exemption)5 years22 July 2011 – 21 July 201622 July 2011 – specified date
8, 9 (medical and monitoring and control devices)7 years22 July 2014 – 21 July 202122 July 2014 – specified date
8 (in vitro diagnostic medical devices)22 July 2016 – 21 July 202322 July 2016 – specified date
9 (industrial monitoring and control instruments)22 July 2017 – 21 July 202422 July 2017 – specified date