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RoHS Directive (recast)
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European Commission RoHS Page
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"Blue Guide" on Implementation of EU Product Rules

European Union


The EU adopted the Restriction of Hazardous Substances Directive (2002/95/EC), “RoHS” in 2003, and it took effect on July 1, 2006.  Directive 2011/65/EC (“RoHS 2” or  “RoHS Recast”), which replaced the original Directive, allows for updating the list of restricted chemicals and exemptions, and has provisions to harmonize RoHS with other EU legislation including REACH.

RoHS restricts the use of six substances in electrical and electronic equipment. Restricted substances have a maximum concentration value tolerated by weight in homogeneous materials:
  • Cadmium (0.01 %)
  • Hexavalent chromium (0.1 %)
  • Lead (0.1 %)
  • Polybrominated biphenyls (PBB) (0.1 %)
  • Polybrominated diphenyl ethers (PBDE) (0.1 %)
  • Mercury (0.1 %)

Additional substances may be restricted in the future.  Priority substances for potential addition are hexabromocyclododecane (HBCDD), bis (2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP).

The maximum permitted concentrations apply for each homogeneous material in the product, which means that the limits do not apply to the weight of the finished product, or even to a component, but to any material in the product that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing or cutting.

Compliance is the responsibility of the party placing the EEE on the market in the EU.  This includes manufacturers of EEE, with certain obligations on importers, distributors, and authorized representatives.  However, since restrictions apply at the homogeneous material level, data on substance concentrations need to be transferred through the supply chain, and thus material and component suppliers often need to certify RoHS compliance to their customers.

The CE mark is the permitted indication of RoHS compliance.  A product sold with the CE mark must meet RoHS requirements (as well as other requirements associated with the CE mark).

Electrical and Electronic Equiptment


The categories of electrical and electronic equipment (EEE) covered by the RoHS directive are:

  • Consumer equipment
  • Lighting equipment
  • Electrical and electronic tools
  • Toys, leisure and sports equipment
  • Medical devices
  • Automatic dispensers
  • IT and telecommunications equipment
  • Small household appliances
  • Large household appliances
  • Other EEE not covered by any of the categories above
  • Monitoring and control instruments including industrial monitoring and control instruments

The following are specifically exempt from the Directive:

  • Large-scale stationary industrial tools
  • Large-scale fixed installations
  • Most means of transport for persons or goods
  • Equipment designed to be sent into space
  • or does not fall within the scope of RoHS
  • Active implantable medical devices
  • Non-road mobile machinery made available exclusively for professional use
  • Equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis
  • Certain equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded 
  • 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
  • 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

In addition, there is a procedure for applying for exemptions for specific applications, and many of these have been granted.  The exempted applications are listed in Annex III and Annex IV of the current Directive.

Manufacturers of EEE.


Manufacturers that place EEE on the market generally must:

  • ensure that it has been designed and manufactured in accordance with RoHS requirements set out in Article 4;
  • draw up technical documentation and a declaration of conformity, and affix the CE marking on the finished product;
  • keep the technical documentation and the declaration of conformity for 10 years after the EEE has been placed on the market;
  • keep a register of non-conforming EEE and product recalls, and keep distributors informed thereof;
  • ensure that their EEE bears a type, batch or serial number or other element allowing its identification, or, where the size or nature of the EEE does not allow it,  that the required information is provided on the packaging or in a document accompanying the EEE;
  • indicate their name, registered trade name or registered trade mark and the address at which they can be contacted on the EEE or, where that is not possible, on its packaging or in a document accompanying the EEE; and
  • for EEE placed on the market that is not in conformity, immediately take the necessary corrective measures to bring that EEE into conformity, to withdraw it or recall it, if appropriate, and immediately inform the applicable competent national authorities.
In the case of an imported product, the Directive lays out the responsibilities of the importer, which are similar to what would be required of the EU manufacturer (if the product were made in the EU).

The materials available and information provided at the Avery Dennison ADvantage: Complete Compliance site are for informational purposes only and not for the purpose of providing legal advice.