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# UK RoHS Regulations: Hazardous Substances Compliance Guide

The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (as amended) restrict 10 hazardous substances in EEE placed on the Great Britain market. Compliance requires supply chain diligence, testing, and comprehensive technical documentation.

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## Restricted substances and limits

Substance

Limit

Common uses

Lead (Pb)

0.1% (1000 ppm)

Solder, glass, ceramics, batteries

Mercury (Hg)

0.1% (1000 ppm)

Switches, relays, lamps

Cadmium (Cd)

0.01% (100 ppm)

Pigments, coatings, batteries

Hexavalent Chromium (CrVI)

0.1% (1000 ppm)

Corrosion protection, pigments

Polybrominated Biphenyls (PBB)

0.1% (1000 ppm)

Flame retardants in plastics

Polybrominated Diphenyl Ethers (PBDE)

0.1% (1000 ppm)

Flame retardants in plastics

Bis(2-ethylhexyl) phthalate (DEHP)

0.1% (1000 ppm)

Plasticizers, softeners

Butyl benzyl phthalate (BBP)

0.1% (1000 ppm)

Plasticizers, adhesives

Dibutyl phthalate (DBP)

0.1% (1000 ppm)

Plasticizers, printing inks

Diisobutyl phthalate (DIBP)

0.1% (1000 ppm)

Plasticizers, coatings

## Compliance process

01

### Product scope verification

Confirm your product falls within the scope of the RoHS Regulations—electrical and electronic equipment (EEE) with voltage rating up to 1000V AC or 1500V DC.

02

### Supplier declarations and material declarations

Obtain material declarations from suppliers for all components and sub-assemblies. Request documentation on substance content and compliance status.

03

### Testing and analysis (if necessary)

Conduct XRF screening or chemical analysis if supplier documentation is insufficient or for high-risk components. Labs can perform IEC 62321 testing.

04

### Technical documentation compilation

Create technical documentation showing compliance including product description, supplier declarations, test reports, and compliance assessment.

05

### Declaration and marking

Prepare UK Declaration of Conformity for RoHS. Affix UKCA marking to the product, packaging, or documentation as required.

## Technical documentation

RoHS technical documentation must demonstrate compliance with substance restrictions:

*   Product description and model variants
*   Bill of materials (BOM) with component details
*   Supplier declarations and material declarations (MDs)
*   Test reports (XRF screening, chemical analysis)
*   Exemption documentation (if applicable)
*   Compliance assessment and justification
*   UK Declaration of Conformity

Documentation must be maintained for 10 years and provided to authorities upon request. Proper documentation is essential for demonstrating due diligence in case of market surveillance.

## Exemptions and special cases

RoHS exemptions allow restricted substances in specific applications where elimination is technically or scientifically impractical. Exemptions are time-limited and subject to regular review by authorities.

Common exemption categories include: lead in glass and ceramics; lead in solders for certain applications; mercury in specific lamps and switches; cadmium in photovoltaic panels; and various medical device and monitoring equipment applications.

If applying an exemption, manufacturers must document which exemption is used, justify its applicability, and track exemption expiry dates. Products using exemptions must still meet all other RoHS requirements.

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## Frequently asked questions

### Does RoHS require UKCA marking?

Yes, electrical and electronic equipment within RoHS scope requires UKCA marking for the Great Britain market. The RoHS Regulations are enforced alongside other applicable product regulations like EMC and electrical safety.

### Are there RoHS exemptions?

Yes, specific exemptions exist for certain applications where alternatives are not technically or scientifically feasible. Exemptions are time-limited and regularly reviewed. Common exemptions include certain lead uses in glass and ceramics, and specific medical and monitoring equipment applications.

### Do cables and accessories need RoHS compliance?

Yes, cables and electrical accessories generally fall within RoHS scope. Cables with a rated voltage up to the specified limits and intended for use with EEE are typically covered by the regulations.

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Educational resource only. RoHS substance restrictions are regularly updated. Always verify current requirements and exemption lists.