[Home](/)/[Resources](/resources)/RoHS 10 Restricted Substances CE / EURoHSChemical Compliance # RoHS 10 Restricted Substances: Limits, Exemptions, and Testing Requirements EU RoHS Directive 2011/65/EU, as extended by (EU) 2015/863, restricts 10 hazardous substances in electrical and electronic equipment. The compliance framework turns on one concept that trips up most manufacturers: maximum concentration values apply at the level of the homogeneous material — not the component, not the product. This guide covers all 10 MCVs, the Annex III exemptions that keep lead solder legal, and the IEC 62321 testing methodology. 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) Lead (Pb) MCV 0.1% by weight in homogeneous material Cadmium (Cd) MCV 0.01% — most stringent limit Phthalates added by amendment (EU) 2015/863, effective 22 July 2019 ## RoHS restricted substances — limits and testing framework ### The 10 restricted substances and their MCVs RoHS 2011/65/EU as amended by (EU) 2015/863 restricts 10 substances. Lead (Pb): 0.1% by weight in homogeneous material. Mercury (Hg): 0.1%. Cadmium (Cd): 0.01% — the only substance with a lower threshold. Hexavalent Chromium (Cr VI): 0.1%. Polybrominated Biphenyls (PBB): 0.1%. Polybrominated Diphenyl Ethers (PBDE): 0.1%. The four phthalates added by (EU) 2015/863 with effect from 22 July 2019: Bis(2-ethylhexyl) phthalate (DEHP) 0.1%, Butyl benzyl phthalate (BBP) 0.1%, Dibutyl phthalate (DBP) 0.1%, and Diisobutyl phthalate (DIBP) 0.1%. All limits are weight percentages within a homogeneous material — not within the product, the component, or the assembly. ### The homogeneous material rule — the most misunderstood concept Maximum concentration values apply at the level of the homogeneous material — defined in Article 3(1)(f) as a material of uniform composition throughout that cannot be mechanically disjointed into different materials. This is not the component, not the PCB, not the cable assembly. A cable has multiple homogeneous materials: the copper conductor, the insulation jacket, and the screen braid are each assessed separately. A solder joint is a homogeneous material — if it is a tin-lead (SnPb) solder, the joint itself is the homogeneous material and Lead content in that joint is the relevant measurement. This is why lead solder exemptions are critical: SnPb solder joints routinely contain 30–40% lead by weight, far above the 0.1% MCV. ### Key Annex III exemptions — lead solder and beyond Annex III lists categories of uses that are exempt from the lead (and other substance) restrictions. Critical exemptions for electronics: Exemption 6(a): Lead in glass of cathode ray tubes. Exemption 6(c): Lead in glass of electronic components other than cathode ray tubes (permits lead in lead crystal glass, glass of components containing glass). Exemption 7(a): Lead in high melting point type solders (tin-lead solder alloys containing more than 85% lead) — used in power electronics where joints must withstand high temperatures. Exemption 15: Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages. Exemption 6(c)-I: Lead as alloying element in steel for machining purposes with lead content up to 0.35% by weight and in batch hot-dip galvanizing. ### Phthalates: the (EU) 2015/863 amendment The four phthalates (DEHP, BBP, DBP, DIBP) were added to the RoHS restricted substances list by Commission Delegated Directive (EU) 2015/863, which amended Annex II of RoHS 2. These phthalates became enforceable for most EEE categories from 22 July 2019. The phthalates are plasticisers commonly found in PVC cables, plastic housings, and rubber seals. DEHP is the most prevalent — it was the dominant flexible PVC plasticiser before the RoHS amendment and is still present in legacy materials and supply chains in Asia. Confirming phthalate compliance requires explicit material declarations from PVC and rubber suppliers; XRF cannot detect phthalates — wet chemical analysis (GC-MS per IEC 62321-8) is required. ### IEC 62321 series — the testing standard for RoHS substances IEC 62321 is the internationally recognised test standard series for determining restricted substance content in electrotechnical products. Key parts: IEC 62321-4 (Pb, Cd, Cr, Hg, and other metals — by ICP-OES after acid digestion), IEC 62321-5 (Cd specifically), IEC 62321-6 (PBDE and PBB by GC-MS), IEC 62321-7-1 (Cr VI by colorimetric method), IEC 62321-7-2 (Cr VI by electrothermal atomic absorption), IEC 62321-8 (phthalates by GC-MS). The EU does not mandate IEC 62321 by law, but it is referenced in the European Commission guidance and accepted by market surveillance authorities. Test results obtained under IEC 62321 methods carry the most weight in demonstrating compliance. ### XRF screening vs confirmatory wet chemical testing X-Ray Fluorescence (XRF) is a fast, non-destructive screening technique that can detect metals including lead, cadmium, mercury, chromium, and bromine (a proxy for PBB/PBDE). XRF is widely used as a first-pass screening tool because it is rapid (seconds per measurement) and non-destructive, allowing the component to survive testing. However, XRF has limitations: it cannot detect hexavalent vs trivalent chromium — total chromium only; it cannot detect phthalates; its accuracy near MCVs is insufficient for definitive declaration, especially for cadmium at 0.01%; and it measures a surface zone, not the full bulk of the homogeneous material. Where XRF gives a result near or above the MCV, confirmatory wet chemical testing per IEC 62321 is required before a compliance declaration can be issued. ## RoHS compliance process — step by step 01 Map the product bill of materials (BOM) to identify all homogeneous materials. For each electrical/electronic component, obtain the material composition from the supplier. Use the IPC-1752A Material Declaration format or IEC 62474 Material Declaration Database to collect standardised material data. 02 For each homogeneous material in the BOM, request a RoHS compliance declaration from the supplier. Tier-1 suppliers of components should provide either an IEC 62321-method test report or a declaration supported by their own supply chain data. IMDS (International Material Data System) entries are accepted in the automotive supply chain. 03 Screen high-risk materials by XRF. High-risk materials include: SnPb solder (if still present), surface coatings (hexavalent chromium used in passivation), polymer components (phthalates in PVC, brominated flame retardants as proxy for PBDE/PBB), and cables. XRF screening takes minutes per part and flags materials requiring further analysis. 04 Where XRF shows a substance near or above the MCV, commission confirmatory IEC 62321 wet chemical testing. For lead in solder joints: IEC 62321-4 (ICP-OES after acid digestion). For phthalates in PVC cables or housings: IEC 62321-8 (GC-MS). For hexavalent chromium in surface coatings: IEC 62321-7-1 (colorimetric method). 05 Review test results against MCVs at the homogeneous material level. Cadmium at 0.01% is the most stringent — even small contamination in plating or pigments can trigger a failure. Document the pass/fail assessment against each of the 10 substances for each homogeneous material. 06 Check Annex III and Annex IV of RoHS for applicable exemptions where substances exceed their MCV. Document the specific exemption number, the duration of the exemption (most exemptions have an expiry date — check the current validity), and the justification for relying on it. 07 Compile the RoHS Technical File: BOM with material declarations, test reports, XRF screening records, exemption justifications, supplier declaration records, and the conformity assessment conclusion. The technical file is not submitted to any authority proactively — it is retained by the manufacturer and produced on request by market surveillance authorities. 08 Issue the EU Declaration of Conformity referencing Directive 2011/65/EU (as amended by (EU) 2015/863) and the applicable harmonised standards (EN IEC 63000 for the DoC and technical documentation requirements). The DoC must identify the manufacturer, authorised representative if applicable, and the product. 09 Affix the CE mark. RoHS compliance is a condition of CE marking for EEE in scope — a product cannot bear the CE mark if it is non-compliant with RoHS. Retain the technical file and DoC for 10 years from the date of placing on the market. 10 Maintain supply chain surveillance. RoHS exemptions have defined expiry dates and must be renewed by the European Commission — once an exemption expires, the substance restriction applies without exception. Set calendar reminders against exemption expiry dates relevant to your product's bill of materials. ## Frequently asked questions ### What does 'homogeneous material' mean for RoHS testing? A homogeneous material under RoHS Article 3(1)(f) is a material of uniform composition throughout that cannot be mechanically disjointed into different materials — meaning it cannot be separated into physically distinct materials by tools such as cutting, crushing, grinding, or abrasive processes. The test for homogeneity is mechanical separability, not chemical bonding. A PCB solder joint is a homogeneous material; the PCB substrate (FR4) is a different homogeneous material; the copper traces are another. The RoHS MCVs apply to the weight of a restricted substance as a fraction of the total weight of that single homogeneous material — not the weight of the component or the product. This distinction is the reason lead solder exemptions exist: a SnPb solder joint is ~37% lead by weight, grossly exceeding the 0.1% MCV, so an Annex III exemption is required. ### Do all 10 RoHS substances have the same maximum concentration value? No. Nine of the 10 restricted substances have a maximum concentration value of 0.1% by weight in homogeneous material. Cadmium (Cd) is the exception — its MCV is 0.01%, which is 10 times more stringent. This reflects cadmium's higher acute toxicity. In practice, the cadmium limit is the most frequently tripped MCV in electronics supply chains because cadmium can appear as a trace contaminant in zinc plating, yellow pigments in plastics, and nickel-cadmium compounds in some coatings. XRF screening for cadmium near 0.01% requires a well-calibrated instrument and is often confirmed by ICP-OES even for apparently passing XRF results. ### How is XRF testing used for RoHS compliance? XRF (X-Ray Fluorescence) is used as a non-destructive first-pass screening tool to identify homogeneous materials likely to contain restricted substances above their MCVs. The technique measures elemental composition from a surface zone of the material — it detects lead, cadmium, mercury, total chromium (not hexavalent chromium specifically), and bromine (a proxy for PBDE/PBB presence). XRF results below approximately 50% of the MCV are generally considered to confirm absence for declaration purposes. Results near or above the MCV — particularly for cadmium at 0.01% — require confirmatory wet chemical testing per IEC 62321 before a compliance declaration can be made. XRF cannot detect phthalates (DEHP, BBP, DBP, DIBP) because these are organic compounds with no detectable elemental signature under XRF — phthalate compliance always requires GC-MS. ### What exemptions cover lead solder in electronics? The primary exemptions for lead solder are in Annex III of RoHS 2011/65/EU. Exemption 6(a) covers lead in glass of CRTs (now largely obsolete). Exemption 7(a) covers lead in high melting point type solders — specifically tin-lead alloys with more than 85% lead content (e.g., Pb92.5Sn5Ag2.5), used in power electronics, military, and aerospace applications where the solder joint must survive elevated operating temperatures. Exemption 15 covers lead in solders used to form a reliable electrical connection between a semiconductor die and carrier in flip-chip IC packages. For standard SnPb eutectic solder (63% tin, 37% lead) used in general PCB assembly, there is no current valid exemption — products using eutectic SnPb solder for general assembly must migrate to lead-free solders or obtain a product-category-specific exemption if applicable. **Disclaimer:** Educational resource only. Regulatory requirements change. 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. 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