RoHS 3: the 10 restricted substances explained

RoHS 3 compliance is often described as a test for ten substances. That is the headline, not the whole job. The restriction applies to in-scope electrical and electronic equipment at maximum concentration values in homogeneous materials, with limited exemptions that need checking. The four phthalates added by Delegated Directive (EU) 2015/863 are why people say ‘RoHS 3’; the legal framework remains RoHS Directive 2011/65/EU.

TL;DR

RoHS 3 compliance means controlling lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and four phthalates in in-scope electrical and electronic equipment. Most limits are 0.1% by weight in homogeneous material; cadmium is 0.01%. The useful rule is simple: decide the scope before commissioning work, retain evidence that identifies the actual product, and review it whenever the product or supply chain changes.

What the decision is really about

RoHS 3 compliance means controlling lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and four phthalates in in-scope electrical and electronic equipment. Most limits are 0.1% by weight in homogeneous material; cadmium is 0.01%. Teams get into trouble when they treat the visible label, certificate or checklist as the beginning of compliance. It is the end of a chain that starts with an accurate product description. Write down the model, intended use, users, markets, components and functions. That short note gives engineering, purchasing and whoever approves packaging the same facts to work from. It also stops a perfectly good report being attached to a slightly different product six months later.

The European regulatory framework is deliberately product-specific. A decision that is sound for one product can be wrong for the next even when they share a supplier or a casing. That is not a reason to overcomplicate every launch. It is a reason to record the boundary of the decision, the evidence used and the owner who will revisit it after a meaningful change.

The questions worth answering before release

The table is a working aid, not legal advice. Its value is in making assumptions visible early, when changing a part or updating an instruction is still easy. Keep it next to the bill of materials and the product record rather than letting it disappear into a quotation email.

A practical working sequence

• Create a bill of materials with supplier and revision, not only commercial part numbers.
• Request specific declarations for materials and components rather than relying on an email claim.
• Escalate PVC, solder, pigments, coatings and older stock for stronger evidence or targeted testing.
• Record any exemption with its legal citation, scope and expiry review date.
• Sign the RoHS part of the declaration only when the file supports the actual product.

Do those steps in that order. Starting with a lab quote, a label proof or a supplier certificate can feel productive, but it can also hard-code the wrong assumption into the project. The better sequence is to establish what the finished product is and which route applies, then ask for the exact evidence that route needs. That makes quotes clearer and makes it much easier to explain why a particular report, declaration or record is in the file.

Evidence that holds up when someone asks

XRF screening can help with some elements, especially metals, but it is not a complete RoHS 3 conclusion. The four phthalates need different methods and one sample cannot prove every assembly is controlled. A proportionate file combines supplier material information, targeted analysis where risk justifies it and change control that prevents an answer quietly expiring after a component substitution.

The best files are boring in the best sense: each document has a date, version, product link and owner. An engineer who was not part of the original project should be able to follow the trail without guessing which attachment is final. A retailer, customs officer or market-surveillance authority is not looking for an enormous folder; they need a clear account of why the product meets the requirements claimed. See what goes in a technical file for a useful shared structure.

Keep the decision live after launch

The RoHS 3 compliance decision should not become invisible after the first shipment. Build a short review into ordinary product change control. Ask whether a proposed change affects the product description, market, intended user, materials, radio function, supplier, software, lab evidence, declaration or label. Most changes will not require starting again. The point is to make a considered decision before the change is released, with a note that someone can find later.

This is also where the person closest to the product needs a route to raise uncertainty without being treated as a blocker. A buyer may see a new material first. A support colleague may hear that a customer uses the product in a way the instructions never anticipated. An engineer may know that a firmware release alters a performance limit. Each observation can be recorded as a review trigger, checked against the original evidence, and closed with a short explanation. That approach is simpler than a giant annual audit because it catches changes while the people who understand them are still in the room.

For RoHS 3 compliance, give that review a named owner and a realistic deadline. A task assigned to ‘compliance’ is usually a task assigned to nobody. A small, visible record of decisions is better than a perfect-looking dashboard that cannot explain why a product is green.

Mistakes that create avoidable rework

• Calculating concentration against the total finished product instead of each homogeneous material.
• Assuming a supplier PDF covers a substitute component.
• Using an exemption without checking its scope or validity.
• Treating one XRF screen as evidence for phthalates or every assembly.

None of these errors are fixed by adding more confident wording to a declaration. The manufacturer or responsible economic operator still needs to understand the claim and have evidence for the exact configuration placed on the market. Supplier documents, test reports and software records are valuable inputs, but responsibility does not move just because a PDF has a reassuring title.

A realistic pre-launch moment

A buyer substitutes a cheaper USB cable from an approved supplier. The connector works, so the order code changes without a review. A change-control question asks whether the PVC formulation is the same and whether the declaration names the new cable. The answer takes an afternoon before release, not weeks after a customer asks.

The point is not that every change needs a panic. It is that a named review gate makes the sensible response routine: record what changed, ask whether the evidence remains representative, update the file if it does not, and only then release the product. That is calmer than rediscovering the issue when stock is already in a warehouse.

What to do next

Start with the bill of materials, then compare RoHS compliance explained and REACH versus RoHS. Start by mapping one live product in the requirements checker. Once the underlying work is complete, the Declaration of Conformity generator can turn the verified details into a consistent document.