[Home](/)/[Resources](/resources)/RoHS 10 Restricted Substances CE / EURoHSChemical Compliance # RoHS 10 Substances: Limits, Exemptions and Testing Requirements The RoHS 10 substances are lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and four phthalates (DEHP, BBP, DBP, DIBP). Each is limited to 0.1% by weight — cadmium to 0.01% — in every homogeneous material of an electrical or electronic product, under Annex II of Directive 2011/65/EU as amended by Delegated Directive (EU) 2015/863. This guide gives the full limits table, the phthalate application dates, the lead exemptions that now expire in 2026–2027, and how IEC 62321 testing fits together. For scope, CE marking and the wider conformity process, see the [RoHS Directive compliance guide](/guides/rohs-directive-compliance). Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Feu-rohs-10-substances-limits) At a glance Number of substances 10 (original 6 + 4 phthalates) Limit (9 substances) 0.1% by weight per homogeneous material Cadmium (Cd) limit 0.01% — the strictest Phthalates apply from 22 July 2019 (cat. 8 and 9: 22 July 2021) Key lead exemptions Most expire 30 June or 31 Dec 2027 ## RoHS 10 substances and limits at a glance All limits are maximum concentration values by weight in a homogeneous material (Annex II, Directive 2011/65/EU). 0.1% equals 1,000 ppm; 0.01% equals 100 ppm. Substance Limit Where it turns up Test method Lead (Pb) 0.1% Solder, free-machining steel, brass and aluminium alloys, PVC stabilisers, glass and ceramics XRF screen; IEC 62321-5 Mercury (Hg) 0.1% Discharge lamps and backlights, tilt switches, some relays XRF screen; IEC 62321-4 Cadmium (Cd) 0.01% Pigments in plastics, legacy platings, PVC stabilisers, contaminated recycled metals XRF screen; IEC 62321-5 Hexavalent chromium (Cr(VI)) 0.1% Chromate passivation on zinc-plated fasteners and brackets IEC 62321-7-1 (coatings), 62321-7-2 (polymers) Polybrominated biphenyls (PBB) 0.1% Legacy brominated flame retardants in plastics Bromine screen; IEC 62321-6 Polybrominated diphenyl ethers (PBDE) 0.1% Brominated flame retardants in housings, connectors, cable jackets Bromine screen; IEC 62321-6 Bis(2-ethylhexyl) phthalate (DEHP) 0.1% Flexible PVC cables, sleeving, grommets, power cords IEC 62321-8 Butyl benzyl phthalate (BBP) 0.1% Adhesives, sealants, vinyl coatings IEC 62321-8 Dibutyl phthalate (DBP) 0.1% PVC, inks, adhesives, rubber parts IEC 62321-8 Diisobutyl phthalate (DIBP) 0.1% PVC, rubber, adhesives (often a DBP substitute) IEC 62321-8 ## How the RoHS limits work ### Where the limits come from Article 4(1) of Directive 2011/65/EU (RoHS 2) prohibits placing electrical and electronic equipment (EEE), including cables and spare parts, on the EU market if it contains the substances listed in Annex II above the maximum concentration values (MCVs). Annex II originally listed six substances carried over from RoHS 1 (2002/95/EC). Commission Delegated Directive (EU) 2015/863 replaced Annex II and added four phthalates, taking the list to ten. No substance has been added since — the Commission considered TBBPA and MCCPs after an Oeko-Institut review but did not proceed with adding them. ### The homogeneous material rule — the most misunderstood concept Annex II limits are "maximum concentration values tolerated by weight in homogeneous materials". Article 3(20) defines a homogeneous material as one material of uniform composition throughout, or a combination of materials that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. So the limit is not measured against the product, the PCB or the component. A cable has at least three homogeneous materials: the copper conductor, the insulation and the outer jacket. A tin-lead solder joint is roughly 37% lead — far above 0.1% — which is why lead solder only survives where an Annex III exemption applies. ### Phthalates: two application dates, plus carve-outs The DEHP, BBP, DBP and DIBP restriction applied from 22 July 2019 for most EEE. For medical devices (including in vitro diagnostic devices) and monitoring and control instruments (including industrial ones) it applied from 22 July 2021. Annex II also says the phthalate restriction does not apply to cables or spare parts used to repair, reuse, update or upgrade EEE placed on the market before those dates, and that the DEHP, BBP and DBP restriction does not apply to toys already covered by REACH Annex XVII entry 51. XRF cannot detect phthalates — they are organic compounds with no elemental fingerprint — so phthalate evidence comes from supplier declarations backed by GC-MS testing to IEC 62321-8. ### Exemptions are time-limited — and many expire in 2026–2027 Annex III (all EEE) and Annex IV (medical devices and monitoring and control instruments) list applications where a substance may exceed its MCV. Each entry has an expiry date. In September 2025 the Commission adopted three delegated directives — (EU) 2025/1802, 2025/2363 and 2025/2364, published 21 November 2025 and applied by Member States from 1 July 2026 — that renewed the core lead exemptions 6(a), 6(b), 6(c), 7(a), 7(c)-I and 7(c)-II only for short periods and split several into narrower, application-specific entries. Under Article 5(5), an exemption stays valid while a renewal application submitted at least 18 months before expiry is pending, so always check the current consolidated Annex III rather than an old list. ### IEC 62321 — the test method series IEC 62321 (published in Europe as EN IEC 62321) is the standard toolbox for measuring RoHS substances: Part 3-1 XRF screening, Part 3-2 total bromine by combustion ion chromatography, Part 4 mercury, Part 5 cadmium, lead and chromium by AAS, AFS, ICP-OES or ICP-MS, Part 6 PBB and PBDE by GC-MS, Part 7-1 Cr(VI) in metal coatings by the colorimetric method, Part 7-2 Cr(VI) in polymers and electronics, and Part 8 phthalates by GC-MS or Py/TD-GC-MS. RoHS does not legally mandate IEC 62321, but it is what labs, customers and market surveillance authorities expect to see. ### XRF screening vs confirmatory wet chemistry XRF is fast and non-destructive, which makes it the standard first pass for lead, mercury, cadmium, total chromium and bromine. Its limits matter: it reports total chromium, not Cr(VI); it cannot see phthalates; bromine only tells you a brominated flame retardant may be present, not whether it is PBB or PBDE; and accuracy near the 0.01% cadmium limit depends heavily on calibration and sample geometry. Results in the inconclusive band around an MCV need confirmation by the relevant IEC 62321 wet chemical method before you rely on them in a declaration. ## Key lead exemptions and their expiry dates Status after Commission Delegated Directives (EU) 2025/1802, 2025/2363 and 2025/2364 (applicable from 1 July 2026). Several 6(x) entries do not cover consumer EEE small enough to be put in the mouth by children unless a lead-release test is passed. Always confirm against the latest consolidated Annex III on EUR-Lex. Entry Covers Status (October 2026) 6(a) Lead in machining steel and galvanised steel, up to 0.35% Pb Expires 11 December 2026. Split into 6(a)-I (machining steel, up to 0.35%) and 6(a)-II (batch hot-dip galvanised steel, up to 0.2%), both to 30 June 2027 6(b) Lead in aluminium alloys, up to 0.4% Pb Replaced by narrower sub-entries 6(b)-I to 6(b)-III, expiring between 11 December 2026 and 30 June 2027 depending on sub-entry and category 6(c) Copper alloys (brass) containing up to 4% Pb Expires 30 June 2027 7(a) High melting temperature solders (85% or more lead) General entry expires 30 June 2027. Replaced by seven application-specific entries 7(a)-I to 7(a)-VII, each to 31 December 2027 7(c)-I Lead in glass or ceramic in components (not capacitor dielectric), e.g. piezoelectronic devices, or in glass or ceramic matrix compounds Expires 30 June 2027. New narrower entries 7(c)-V (glass) and 7(c)-VI (PZT and PTC ceramics) run to 31 December 2027 7(c)-II Lead in dielectric ceramic of capacitors rated 125 V AC / 250 V DC or higher Expires 31 December 2027 ## RoHS compliance process — step by step 01 Confirm the product is EEE in RoHS scope (Article 2 and Annex I) and note its category — categories 8 (medical devices) and 9 (monitoring and control instruments) have different phthalate dates and use Annex IV exemptions as well as Annex III. 02 Break the bill of materials down to homogeneous materials. Collect full material declarations from suppliers, ideally in IPC-1752A or IEC 62474 format, so every material has substance-level data rather than a one-line "RoHS compliant" claim. 03 Rank parts by risk. High-risk: anything with flexible PVC (phthalates), solder and brass or free-machining steel (lead), zinc-plated hardware (Cr(VI)), coloured or recycled plastics (cadmium, brominated flame retardants), and parts from low-tier or unaudited suppliers. 04 Screen high-risk materials by XRF per IEC 62321-3-1. Send anything inconclusive or near an MCV, and every PVC or rubber part where phthalate data is missing, for IEC 62321 wet chemistry. 05 Assess each homogeneous material against all ten MCVs. Where a material exceeds a limit, identify the exact Annex III or Annex IV entry relied on, the category it applies to, and its expiry date. 06 Compile the technical documentation in line with EN IEC 63000:2018 (the harmonised standard for RoHS technical documentation): scope assessment, supplier declarations, test reports, exemption justifications and the risk-based reasoning behind your sampling. 07 Draw up the EU Declaration of Conformity referencing Directive 2011/65/EU and, where used, EN IEC 63000:2018. RoHS can be in a single combined DoC with the other CE directives that apply to the product. 08 Affix the CE marking. RoHS is one of the CE marking directives for EEE, so non-compliance with RoHS means the CE marking is wrongly applied. 09 Keep the technical documentation and DoC for 10 years after the product is placed on the market, as Article 7 requires of manufacturers. 10 Track exemption expiry dates against your BOM. With most core lead exemptions now running to mid or late 2027, plan design changes or confirm renewal applications well before the dates in the exemption table. ## Common RoHS mistakes ### Measuring against the whole component Grinding a whole connector and reporting 0.05% lead hides a brass contact that may be at 3%. Limits apply to each homogeneous material, so sample each material separately. ### Treating XRF as proof of phthalate compliance A clean XRF scan says nothing about DEHP or DIBP. Cables, sleeving and grommets need GC-MS data or a declaration backed by it. ### Citing an exemption without its sub-entry or expiry Since the 2025 delegated directives, "7(a)" alone is no longer enough — the general entry ends 30 June 2027 and use after that must fit one of 7(a)-I to 7(a)-VII. Record the exact sub-entry and date. ### Confusing RoHS with REACH and SCIP Passing RoHS does not cover REACH Article 33 duties or SCIP notifications for Candidate List substances such as some lead compounds. They are separate laws with different thresholds and scopes. ## Frequently asked questions ### What are the RoHS 10 substances? The RoHS 10 substances are lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr VI), polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates: DEHP, BBP, DBP and DIBP. They are listed in Annex II of Directive 2011/65/EU as replaced by Delegated Directive (EU) 2015/863. Nine have a limit of 0.1% by weight in each homogeneous material; cadmium is limited to 0.01%. "RoHS 10" or "RoHS 3" is industry shorthand for this ten-substance list — the legal text is still RoHS 2 (2011/65/EU) as amended. ### What is the RoHS limit for lead? The RoHS limit for lead is 0.1% by weight (1,000 ppm) in each homogeneous material. Lead above that level is only allowed where a specific Annex III or Annex IV exemption applies — for example 7(a)-I to 7(a)-VII for high melting temperature solders, 6(c) for copper alloys up to 4% lead, or 7(c)-I for lead in glass or ceramic components — and only until that exemption expires. ### What does 'homogeneous material' mean for RoHS testing? Article 3(20) of Directive 2011/65/EU defines a homogeneous material as one material of uniform composition throughout, or a combination of materials that cannot be separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. A solder joint, the FR4 laminate and the copper traces on a PCB are three different homogeneous materials. The MCVs apply to each one separately, not to the weight of the component or the finished product. ### Do all 10 RoHS substances have the same maximum concentration value? No. Nine have a maximum concentration value of 0.1% by weight in homogeneous material. Cadmium is the exception at 0.01% (100 ppm), ten times stricter. In practice cadmium failures usually come from pigments in coloured plastics, legacy platings and recycled metal feedstock, and XRF results near 100 ppm should be confirmed by IEC 62321-5 testing. ### When did the four phthalates become restricted under RoHS? DEHP, BBP, DBP and DIBP have been restricted since 22 July 2019 for most electrical and electronic equipment. For medical devices (including in vitro diagnostic devices) and monitoring and control instruments (including industrial ones), the restriction applied from 22 July 2021. Cables and spare parts for repairing or upgrading equipment placed on the market before those dates are exempt from the phthalate restriction. ### What exemptions cover lead solder in electronics? Standard tin-lead eutectic solder (about 37% lead) for general PCB assembly has no general exemption in Annex III. Lead in high melting temperature solders (85% lead or more) has been covered by entry 7(a). Delegated Directive (EU) 2025/1802 limits the general 7(a) entry to 30 June 2027 and replaces it with seven narrower entries, 7(a)-I to 7(a)-VII — for example die attach in power semiconductors, first-level solder joints inside components, ceramic BGA solder balls, and hermetic seals — each expiring 31 December 2027. Other solder-related entries, such as the flip-chip exemption 15, should be checked against the current consolidated Annex III because their renewal status can change. ### Which RoHS exemptions expire in 2026 and 2027? Under the delegated directives (EU) 2025/1802, 2025/2363 and 2025/2364, exemption 6(a) for lead in steel expires 11 December 2026, and several 6(b) aluminium sub-entries end between 11 December 2026 and 11 June 2027. Entries 6(a)-I, 6(a)-II, 6(c), the general 7(a) entry and 7(c)-I expire 30 June 2027. The narrower 7(a)-I to 7(a)-VII entries, 7(c)-II, 7(c)-V and 7(c)-VI expire 31 December 2027. In July 2026 the Commission also consulted on a further draft delegated act updating lead and cadmium exemptions in Annexes III and IV, so check whether it has been adopted. ### What is the difference between RoHS, REACH and the SCIP database? RoHS is a product restriction: EEE cannot be placed on the EU market if any homogeneous material exceeds the Annex II limits for the 10 substances. REACH Article 33 is a communication duty: if an article contains a Candidate List substance of very high concern (SVHC) above 0.1% by weight, you must give recipients enough information for safe use, and consumers on request within 45 days. SCIP is the ECHA database where suppliers of such articles have notified that information since 5 January 2021 under Article 9(1)(i) of the Waste Framework Directive. In December 2025 the Commission's Environmental Omnibus proposed repealing the SCIP duty in favour of the Digital Product Passport — until that is adopted and applies, the SCIP obligation stands. A product can pass RoHS and still trigger REACH and SCIP duties, for example for lead in an exempted brass part. ### How is XRF testing used for RoHS compliance? XRF screening under IEC 62321-3-1 is used to triage materials quickly and non-destructively for lead, mercury, cadmium, total chromium and bromine. Clear passes well below the limits are usually accepted as screening evidence; inconclusive results near an MCV, any positive chromium or bromine reading, and all phthalate questions need confirmatory testing with the relevant IEC 62321 wet chemical method (Part 4, 5, 6, 7-1, 7-2 or 8). **Disclaimer:** Educational resource only. RoHS exemptions are amended frequently — check the current consolidated text of Directive 2011/65/EU on EUR-Lex and consult a qualified compliance specialist before making decisions. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/06-rohs-reach-compliance-complete-guide)[Prefer to read? 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