RoHS Compliance
RoHS refers to the Restriction of Hazardous Substances Directive, which aims to tackle the substantial waste stream of electrical and electronic equipment (EEE) containing hazardous substances by restricting the use of certain substances during manufacturing. The original RoHS (Directive 2002/95/EC) was implemented on July 1, 2006 in the European Union and restricted six hazardous substances. In 2011, the directive was recast as RoHS 2 or RoHS-Recast (Directive 2011/65/EU), and was implemented on January 2, 2013. In addition to improvements to regulatory scope and implementation, legal clarity, recordkeeping procedures, and marking requirements, RoHS compliance became a requirement to bear the CE marking. Most recently, RoHS 3 (Directive (EU) 2015/863) took effect on July 22, 2019, adding four new restricted substances along with the catch-all Category 11 defined as “Other EEE not covered by any of the categories above.”
The 10 restricted substances are:
1. Lead (Pb)
2. Mercury (Hg)
3. Cadmium (Cd)
4. Hexavalent chromium (Cr(VI))
5. Polybrominated biphenyls (PBB)
6. Polybrominated diphenyl ether (PBDE)
7. Bis(2-ethylhexyl) phthalate (DEHP)
8. Butyl benzyl phthalate (BBP)
9. Dibutyl phthalate (DBP)
10. Diisobutyl phthalate (DIBP)
The maximum permitted concentrations in non-exempt products are 1000 ppmw or 0.1%, except for cadmium, at 100 ppmw or 0.01%.
What does this mean for your business?
If your company manufactures applicable electronics or electronic equipment for sale, resale, or distribution in the EU or in countries which have implemented RoHS requirements, then RoHS compliance applies to your business. From drones to smart home assistants, with the expanded scope of RoHS and the proliferation of digital technologies, compliance is more relevant than ever today.
Worldwide RoHS Compliance
RoHS has been adopted in various forms by numerous countries outside of the EU. The countries below have or are expecting to implement their own version of RoHS:
China RoHS Compliance
The new China ROHS regulation Order # 32 came into force on 1 July 2016 and restricts the same 6 hazardous substances as EU RoHS 2. The detailed concentration limits are set by GB/T 26572 - the requirements for concentration limits for certain restricted substances in electronic and electrical products.
If all limits are met, a green marking is used. If one or more limits are exceeded, an orange label is used. The pollutants must be identified in Chinese, and disposal or reusability guidance must be provided. The usage period before harmful emissions of the pollutants occurs must also be indicated. This is known as the Environment Friendly Use Period (EFUP).
On 15 March 2018, China MIIT published the first catalogue of electrical and electronic products subject to RoHS compliance management, and a list of RoHS exemption. The catalogue includes 12 categories of electrical and electronic products. Products exceeding the limits are not allowed to be sold in the market. The catalogue came into force on 15 March 2019.
The program and database are managed by the Ministry of Industry and Information Technology (MIIT).
UAE RoHS Compliance
UAE RoHS implementation started from Jan 2018. All EEE products in scope are required to meet the RoHS limits, which restricts the full 10 substances and is the same as EU RoHS 3 in terms of requirements. Companies have two options to comply with UAE RoHS. Companies that have risk assessment documentation and can show full compliance with UAE RoHS requirements can apply to receive a certificate by ESMA that is valid for three years. An Emirates Quality Mark can then be placed on the product. Companies that have not completed a full product assessment may complete a Declaration of Conformity and submit product testing reports to apply for a one-year certification.
Eurasian/Russian RoHS Compliance
The Eurasian Economic Union (EEU) (Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia) passed CU TR 037/2016 on March 1, 2018, with member states having until March 1, 2020 to comply. EAC RoHS is well aligned with EU RoHS.
Taiwan RoHS Compliance
The Bureau of Standards, Metrology & Inspection (BSMI) manages the Taiwan RoHS program, which was implemented in 2016. While similar to EU RoHS regarding the original six restricted substances, it features different effective dates and allows the sale of products exceeding the limits if a Table of Presence Condition of Restricted Substances is added to the packaging and materials accompanying the product.
Korea RoHS Compliance
Implemented in 2008, Korea RoHS restricts the same six original restricted substances following EU RoHS 2 limits for EEE. Korea RoHS applies to TVs, refrigerators, mobile devices, washers (household use only), personal computers, audio equipment, air-conditioners, printers, copiers, and fax machines. Certain products such as batteries, medical devices, and packing materials are out of the scope of Korean RoHS. However, vehicles weighing less than 3.5 tons (defined according to Article 2(1) of the Automobile Management Act) are also subject to limits for cadmium, mercury, lead, and hexavalent chromium. There is no marking or certification requirement.
India RoHS Compliance
Implemented in 2014, India RoHS closely follows EU RoHS, restricting the same six original restricted substances at identical threshold levels. However, the product categories scope is different.
Ukraine RoHS Compliance
Ukraine RoHS was implemented in 2017 and closely follows the more recent EU RoHS 3 by restricting the full 10 substances in all 11 product categories, along with the same exemptions.
Singapore RoHS Compliance (SG-RoHS)
Implemented in 2017 by the Singapore Ministry of the Environment and Water Resources (MEWR), SG-RoHS restricts the original six EU RoHS restricted substances in mobile phones, laptops, flat-panel TVs, refrigerators, air conditioners, and washing machines.
VSCB can guide you through the requirements for the countries above by leveraging RoHS 2 and/or RoHS 3 test reports and compliance declarations. We can also get your product tested at our partner lab in China. Please feel free to contact us at
customer-service@vscbcorp.com