[Home](/)/[Resources](/resources)/RoHS Directive compliance EUDirective guide # RoHS Directive: Restricted Substances and How to Comply RoHS 2 (Directive 2011/65/EU) restricts 10 hazardous substances in electrical and electronic equipment sold in the EU. For most hardware products it is a supply chain compliance exercise — but the documentation behind it has to hold up under audit. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Frohs-directive-compliance) At a glance Restricted substances 10 Example exemptions 5 Doc requirements 7 ## What RoHS actually restricts RoHS 2 restricts the use of 10 substances in electrical and electronic equipment (EEE). The restriction applies at the homogeneous material level — meaning the concentration limit must be met within each individual material that cannot be mechanically separated further, not just averaged across the whole product. The practical implication is that a tiny solder joint that exceeds the lead limit makes the whole product non-compliant, even if the rest of the device is clean. This is why supplier declarations down to the material level — not just the component level — matter. SubstanceLimitCommon uses Lead (Pb)0.1% by weight of homogeneous materialSolder, CRT glass, PVC stabilisers Mercury (Hg)0.1%Fluorescent backlights, switches Cadmium (Cd)0.01%NiCd batteries, pigments, plating Hexavalent chromium (Cr VI)0.1%Corrosion inhibitors, metal finishing Polybrominated biphenyls (PBB)0.1%Flame retardants in plastics Polybrominated diphenyl ethers (PBDE)0.1%Flame retardants in plastics Bis(2-ethylhexyl) phthalate (DEHP)0.1%PVC plasticiser Benzyl butyl phthalate (BBP)0.1%PVC plasticiser Dibutyl phthalate (DBP)0.1%PVC plasticiser Diisobutyl phthalate (DIBP)0.1%PVC plasticiser ## RoHS exemptions you might actually use RoHS has a long list of exemptions — specific uses of restricted substances that are permitted because no viable alternative exists. The most common ones for electronics hardware are listed below. Each has a review cycle and an expiry date. Exemption 6(a) Lead in high melting temperature type solders (Pb ≥85%) — used in power semiconductors and aerospace applications. Exemption 6(c) Lead in ceramic or glass matrix composites (other than in capacitors). Exemption 7(a) Lead in high voltage diodes based on a zinc borate glass body. Exemption 13(a) Lead as an alloying element in steel for machining purposes containing up to 0.35% lead by weight. Exemption 14 Lead in solder for complete and flawless joining of electrical connection between semiconductor die and carrier within integrated circuit Flip Chip packages. ## What documentation you need 01 Supplier declarations of conformity (DoC) from component and material suppliers 02 Material composition data from IPC-1752A or equivalent declaration format 03 Test reports or certificates for high-risk components (solder, cables, finishes) 04 Exemption tracking — if you rely on any RoHS exemptions, document the exemption number, scope, and expiry date 05 BOM-level mapping of restricted substance evidence to specific parts 06 Internal RoHS assessment confirming product-level compliance 07 Retention of all records for at least 10 years after the last unit is placed on the market ## Frequently asked questions ### Does RoHS apply to batteries? RoHS restricts substances in the battery itself as a component within EEE. However, standalone batteries placed on the market separately fall under the Battery Regulation (EU) 2023/1542 rather than RoHS. If a battery ships inside your product, it is a component subject to RoHS. ### What is a homogeneous material in RoHS? A homogeneous material is a material that cannot be mechanically disjointed into different materials — it is uniform throughout. The concentration limits apply per homogeneous material, not per component or per product. A PCB, for example, contains many different homogeneous materials. ### Do I need lab testing to prove RoHS compliance? Not necessarily. Most manufacturers comply with RoHS through a supply chain declaration approach rather than direct chemical testing. You collect material declarations from suppliers (IPC-1752A format) and conduct a documentary assessment. Physical testing (XRF, ICP) is used for spot checks, audit defence, or when supplier declarations are unavailable. ### How do I handle RoHS exemptions? If your product relies on an exemption, document the specific exemption number and reference, the scope it covers in your product, and the exemption expiry date. RoHS exemptions are time-limited and must be renewed by the European Commission. Using an expired exemption means the product is non-compliant even if the exemption previously applied. ### Is RoHS separate from CE marking? Technically, RoHS is a separate legal obligation under EU law — it does not require a CE mark on its own, and affixing a CE mark does not automatically mean RoHS compliance. However, in practice, the CE marking process covers RoHS because the EU DoC and technical file must address all applicable legislation. **Disclaimer:** Educational resource only. Not legal advice. Verify current exemption status, substance limits, and applicable categories against the official RoHS 2 directive and Commission guidance before supplying products to the EU market. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap 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? Get the book — $24.99](/books/06-rohs-reach-compliance-complete-guide) Related guides * [CE marking overviewCE marking is a manufacturer's declaration that a product meets all applicable EU requirements.](/guides/ce-marking) * [REACH regulation and CE markingHow REACH Regulation (EC) 1907/2006 intersects with CE marking for hardware products: SVHC communication duties, Article 33 obl…](/guides/reach-regulation-and-ce-marking) * [WEEE Directive complianceA practical guide to WEEE Directive 2012/19/EU compliance for hardware companies: registration requirements, labelling with the…](/guides/weee-directive-compliance) * [Complete CE documentation bundleA deep guide to the complete CE documentation bundle: Declaration of Conformity, technical file, risk assessment, test evidence…](/guides/complete-ce-documentation-bundle) * [CE marking for consumer electronicsComplete guide to CE marking for consumer electronics: applicable directives, testing requirements, cost breakdown, and realist…](/guides/ce-marking-for-consumer-electronics) * [EU RoHS 10 Restricted Substances and LimitsEU RoHS 2011/65/EU as amended by (EU) 2015/863: all ten restricted substances with their maximum concentration values, the homogeneous material rule, Annex III and IV exemptions including lead solder, and IEC 62321 test methods.](/guides/eu-rohs-10-substances-limits)