RoHS Compliance: The Complete Guide

Ship a product with any electronics inside and RoHS is one of the first things a distributor, a customs officer, or a marketplace compliance bot will check for. Get it wrong and the fallout ranges from a blocked shipment to a full recall, plus a CE mark that quietly stops meaning anything. This guide sets out exactly what RoHS restricts, how the testing actually works down to individual solder joints, and where UK rules have started to pull away from the EU's. The proof point to keep in mind: in the EU's 2025 JACOP market surveillance campaign, 53% of the 173 electronic products tested failed basic hazardous-substance checks first time round.

The 10 substances RoHS restricts, and their thresholds

RoHS stands for Restriction of Hazardous Substances. The original directive dates from 2002, was recast as Directive 2011/65/EU (often called RoHS 2), and was then amended by RoHS 3 (Directive (EU) 2015/863), which added four phthalate plasticisers to the restricted list from July 2019. That's the "latest RoHS directive 2011/65/EU" people search for: it's still the legal core, with 2015/863 bolted on as the substance-list update.

Ten substances are restricted today, each with a maximum concentration allowed per homogeneous material. The table below shows what they are and the limit for each.

Cadmium sits at a tenth of the limit for the others, which trips up more products than you'd expect: some pigments, platings and older cable insulations still use it. RoHS covers almost all electrical and electronic equipment (EEE) sold in the EU or UK, plus cables and spare parts, with only a short list of exclusions such as large fixed installations and some military or medical devices with their own timelines.

RoHS also carries a paperwork tail that outlasts the product itself. Manufacturers are expected to keep their technical documentation and Declaration of Conformity available for ten years after the last unit of a given model is placed on the market, not ten years from when you stopped selling the version currently in your warehouse. If you're still fielding warranty claims on a product line you discontinued five years ago, the RoHS evidence for it should still be sitting somewhere retrievable.

The original driver behind the directive wasn't consumer safety in the way people often assume; it was what happens to electronics at the end of their life. Lead, cadmium and brominated flame retardants leach out of landfilled circuit boards and casings, and they were turning up in soil and groundwater near e-waste processing sites long before RoHS existed. Restricting them at the design stage is cheaper and more effective than separating them out during recycling later, which is why RoHS is usually read alongside the WEEE Directive covering collection and recycling of the same equipment once it's thrown away.

What does "homogeneous material" actually mean for testing?

This is the part that trips up people who assume RoHS is checked against the finished product as a whole. It isn't. Every threshold in the table applies per homogeneous material, meaning the smallest bit of a product that can't be mechanically separated into different materials, not the product, not even a single component.

Take a USB charging cable. It isn't one homogeneous material; it's several: the copper conductor, the PVC insulation around it, the metal shielding braid, the moulded plastic connector housing, and the solder joints inside the plug. Each of those gets tested separately against the 0.1% (or 0.01% for cadmium) limit. A plastic housing that's well within limits sitting next to a solder joint that isn't doesn't average out; the joint fails on its own, and the whole product fails RoHS as a result.

This is why a lab report for a moderately complex electronic product can run to dozens of individual material tests, and why the same component sourced from two different suppliers can have completely different RoHS outcomes even though the finished part looks identical.

Connectors and coloured plastics are worth flagging separately, because they cause a disproportionate share of failures. A connector pin might be plated with several thin layers, an outer nickel finish over a lead-based undercoat, and each layer counts as its own homogeneous material if it can be scraped or peeled apart. Coloured casings are similar: certain older red, yellow and orange pigments used hexavalent chromium or cadmium compounds to get a stable colour, so a supplier switching plastic colour on a whim, even on a part that's otherwise unchanged, can reopen a question you thought was already closed.

How RoHS fits into your CE marking file

RoHS isn't a separate certificate you bolt on afterwards; it's one of the directives your product's CE marking already has to satisfy. If your product is electrical or electronic equipment sold in the EU, RoHS sits alongside directives like the Low Voltage Directive and EMC in the list of legislation your Declaration of Conformity has to reference, and your technical file needs evidence backing that claim.

In practice that means your RoHS test reports, bill of materials, and any exemption references you're relying on all live in the same technical file as your other CE evidence, not in a standalone folder. When you generate your paperwork with a tool like our Declaration of Conformity generator, RoHS is one of the boxes you tick alongside the other applicable directives, and the underlying test evidence needs to actually exist behind that tick. Reviewers and market surveillance officers will ask for the RoHS test report by homogeneous material if a product gets flagged, so "our supplier said it's fine" isn't documentation, it's a rumour.

Most electronic products self-certify RoHS through internal production control rather than going through a notified body, much like the self-assessment route common for other CE directives. That doesn't make it optional or informal; it means the legal weight sits on your own test evidence and your own signature on the Declaration of Conformity, with nobody else checking your homework before the product ships. Worth remembering too that RoHS obligations don't only sit with whoever designed the product. Importers and distributors carry their own duties to check the paperwork exists and looks credible before they put a product on the market, which is why a distributor asking pointed questions about your RoHS file isn't being difficult, it's covering its own legal exposure as well as yours.

RoHS 3 exemptions: how the renewal process actually works

Some uses of restricted substances are technically unavoidable with current technology, so RoHS allows time-limited exemptions listed in Annexes III and IV. Lead in certain solders used in aerospace or medical equipment is a common example; lead as an alloying element in specific steel or aluminium alloys is another.

Exemptions aren't permanent. Each one carries an expiry date, and if industry wants it kept, someone has to apply for renewal no later than 18 months before it lapses. A decision on that renewal typically takes 18 to 24 months from application, which is why exemption lists always look like they're running slightly behind schedule. Helpfully, if a valid renewal application is submitted in time, the existing exemption stays usable until the Commission actually rules, even if the original expiry date on paper has already passed.

The administration of this process is also shifting. Directive (EU) 2025/2456, which entered into force on 1 January 2026, moves the scientific and technical assessment work behind exemptions from the European Commission to the European Chemicals Agency, with the changeover taking full effect from 13 August 2027. If you're relying on an exemption for a product line, it's worth checking the current expiry date and renewal status rather than trusting whatever number is printed on an old datasheet, since several major exemptions covering categories like lead in high-melting-point solders and certain electronic ceramics were all up for renewal in the 2025-2026 cycle.

What does RoHS testing and documentation look like in practice?

For most manufacturers, RoHS compliance is built in three stages, and none of them is a single tick-box.

• Material declarations from suppliers. Before anything gets tested, you need a declaration from each component or material supplier stating what's inside, ideally down to the homogeneous material level. This is the cheapest stage and the one most often skipped, which is where problems start.
• Screening and confirmatory lab testing. X-ray fluorescence (XRF) screening gives a quick read on metals like lead, cadmium and chromium and is used to flag risk areas fast. Where XRF flags something borderline, or for substances it can't reliably detect (the phthalates need a different method entirely), a proper wet-chemistry lab test confirms the actual concentration per homogeneous material.
• The technical file. Test reports, the bill of materials they map to, any exemptions being claimed and their reference numbers, and the manufacturer's own risk assessment all get filed together, ready to produce if a market surveillance authority asks.

Say you're bringing in a battery-powered smart thermostat from a contract manufacturer. You'd expect RoHS test reports for the PCB assembly (solder, PCB laminate, component leads), the plastic enclosure, the internal wiring harness, the battery contacts, and the display module, each broken down by homogeneous material rather than as one bundled "product passed" certificate. If your supplier can only hand you a generic one-page RoHS statement with no test data behind it, that's a gap worth closing before the product ships, not after a spot-check finds it. This is especially common when importing electronics from Chinese manufacturers, where documentation quality varies enormously between suppliers even for near-identical products.

There's no single EU-wide "RoHS compliance certificate" issued by an authority; what you actually get is a set of test reports and a Declaration of Conformity referencing them, which functions as your compliance evidence.

What does "RoHS compliant" actually mean on a declaration?

When a supplier or a product listing says "RoHS compliant," it's making a specific legal claim: every homogeneous material in that product sits under the relevant threshold for all ten restricted substances, unless a valid exemption is being claimed and disclosed. It isn't a general statement about being "eco-friendly" or "lead-free" as a marketing line, even though those phrases get used loosely.

A genuine RoHS compliant claim should be traceable to test data. If you ask a supplier "compliant against which substances, tested when, by which lab" and get a vague answer, treat the claim as unverified rather than accept it at face value. This matters more than it sounds: EU market surveillance officials have been explicit about why campaigns like this exist. As Vanessa Capurso, a DG GROW Policy Officer at the European Commission, put it, describing the 2025 JACOP testing campaign: "Campaigns like JACOP protect European consumers from dangerous appliances and safeguard economic operators from competitors who try to circumvent EU rules." That campaign found lead and cadmium in solder points across 82 of the failing samples, and phthalate plasticisers in cables and power cords in 51 more, which gives a fair sense of where the real risk concentrates: not exotic materials, but ordinary solder and cable insulation.

UK RoHS vs EU RoHS: where the two have diverged

Since Brexit, UK RoHS and EU RoHS have been drifting apart, slowly rather than dramatically, but the gap is now large enough to matter for anyone selling into both markets. Before the end of the Brexit transition period on 31 December 2020, the UK's RoHS Regulations 2012 were "ambulatory," meaning UK exemption lists automatically updated whenever the EU published changes. That link was cut at the end of the transition period, and UK exemption lists were effectively frozen at their December 2020 state.

Since then, any UK update needs its own amending Statutory Instrument laid before Parliament, which runs on a different, generally slower timetable than the EU's exemption process. In practice this means a substance exemption the EU renews or narrows in Brussels doesn't automatically change on the UK side until Westminster separately legislates for it, so a product can technically be RoHS compliant in one market and not, strictly, in the other, even with identical materials. There's also a parallel wrinkle for anyone tracking REACH alongside RoHS: UK REACH has diverged from EU REACH along a similar timeline, and the two regimes are worth checking together rather than assuming one implies the other.

Practically, if you sell the same electronic product under both CE and UKCA markings, keep separate exemption-tracking notes for each market. A five-minute check against both the current EU Annex III/IV list and the current UK equivalent, rather than assuming they still match, will catch this before a customs hold does.

RoHS isn't a one-off certificate you earn and forget; it's a live obligation that shifts every time an exemption expires, a supplier changes a solder alloy, or the UK and EU lists drift a little further apart. If you're not sure where your product currently stands, run it through our free compliance check to see which directives and standards actually apply before you finalise your technical file.