In brief
RoHS refers to EU Directive 2011/65/EU, which restricts the use of certain hazardous substances in electrical and electronic equipment.
Contents
What is RoHS?
The abbreviation RoHS stands for Restriction of Hazardous Substances. Directive 2011/65/EU stipulates that electrical and electronic equipment may contain certain substances only up to specified maximum concentrations. These include lead, mercury, cadmium, hexavalent chromium and the flame retardants PBB and PBDE. Delegated Directive (EU) 2015/863 added four phthalates that are used as plasticisers.
The maximum concentrations refer to homogeneous materials, i.e. to individual materials of a component and not to the device as a whole; a lower value applies to cadmium than to the other substances. For certain applications for which there is not yet a technical substitute, time-limited exemptions are set out in the annexes to the directive. Compliance is part of the conformity assessment and is documented via the CE marking and the EU declaration of conformity.
Special rules apply to spare parts: spare parts for the repair or reuse of certain older equipment may fall under exemptions. RoHS must be distinguished from the chemicals regulation REACH, Regulation (EC) No 1907/2006, which governs substances in general, irrespective of product type.
In practice: maintenance and procurement
For spare parts for electrical and electronic equipment, it should be clarified whether the manufacturer has issued a RoHS compliance statement or whether an exemption applies. In an individual case, the interpretation of the competent authorities is binding; this entry does not constitute legal advice.
Synonyms and abbreviations: RoHS Directive · RoHS 2 · RoHS 3 · Restriction of Hazardous Substances · Directive 2011/65/EU
Frequently asked questions
What is the difference between RoHS and REACH?
RoHS applies only to electrical and electronic equipment and restricts a defined list of substances in it. REACH, Regulation (EC) No 1907/2006, governs the registration, evaluation, authorisation and restriction of chemical substances in general, including in articles of all kinds. A product can therefore be RoHS-compliant and still trigger information obligations under REACH, for example for substances of very high concern.
Which substances does RoHS restrict?
Restricted substances are lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). Delegated Directive (EU) 2015/863 added the phthalates DEHP, BBP, DBP and DIBP. The list thus comprises ten substances, each with maximum concentrations in homogeneous materials.
What is meant by RoHS 2 and RoHS 3?
RoHS 2 is a common name for Directive 2011/65/EU, which replaced the first RoHS directive. RoHS 3 is often used to refer to the extension by Delegated Directive (EU) 2015/863 to include four phthalates. Legally, this is not a separate third directive but an amendment to 2011/65/EU.
Do spare parts have to be RoHS-compliant?
In principle, the restrictions also apply to spare parts. However, the directive provides for exemptions, for example for spare parts for the repair of equipment placed on the market before the respective restriction took effect. Whether an exemption applies depends on the individual case; the interpretation of the competent market surveillance authorities is binding.