RoHS compliance checklist for electronics

RoHS — the Restriction of Hazardous Substances Directive (2011/65/EU), often called RoHS 2 or RoHS Recast — restricts the use of ten hazardous substances in electrical and electronic equipment (EEE) sold in the EU. It applies alongside CE marking, not instead of it: RoHS conformity is one of the things your Declaration of Conformity has to cover if your product falls within EEE scope.

What's actually restricted

The directive limits ten substances to a maximum concentration of 0.1% by weight per homogeneous material, with one exception: cadmium is capped at 0.01%. The restricted list covers four heavy metals (lead, mercury, cadmium, hexavalent chromium) and six flame retardants and plasticisers (PBB, PBDE, and four phthalates — DEHP, BBP, DBP, DIBP).

"Homogeneous material" is the detail people get wrong. It doesn't mean the finished product, or even a single component — it means a material that can't be mechanically separated into different materials, like the solder on a specific joint, the insulation on a specific wire, or the plating on a specific connector. A single circuit board can contain dozens of homogeneous materials, each of which has to individually meet the threshold.

What changes in 2026

The restricted substance list itself hasn't changed. What's moving is the exemption structure in Annex III — RoHS grants time-limited exemptions for specific uses of restricted substances where no viable substitute exists yet (certain lead-based solders in specialised applications are the most common example for hardware startups). Several of those exemptions have narrower renewal wording and revised expiry dates taking effect in 2026, so a product that relied on an exemption two years ago needs that exemption re-checked, not assumed.

Building your compliance file

• Get supplier declarations of conformity or full material declarations (IEC 62474 format is the common standard) for every component and sub-assembly, not just the finished board.
• Cross-reference any restricted-substance use against the current Annex III exemption list — don't rely on a component datasheet that predates the latest amendment.
• Keep the technical documentation, including test reports or supplier declarations, for ten years from the date the last unit was placed on the market.
• If you use a lab test rather than relying purely on supplier declarations, IEC 62321 is the relevant test-method series for the restricted substances.

RoHS conformity feeds directly into your CE Declaration of Conformity — see our Declaration of Conformity guide for how the two documents fit together, or run your product through the free requirements checker to see which other directives apply alongside it.