EU directive
RoHS Directive – 2011/65/EU
Background
Restricted substances in electrical and electronic equipment
RoHS restricts certain hazardous substances in electrical and electronic equipment. The Directive forms part of the CE-marking process and must be handled alongside other applicable product legislation.
Scope
Businesses supplying EEE to the EU market
Manufacturers, importers, and distributors of electrical and electronic equipment are affected. Scope, explicit exclusions, and the product category must be assessed before material requirements can be established.
Requirements
Substance limits, exemptions, and evidence
RoHS restricts lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates. Assessment is performed at homogeneous-material level. Valid exemptions in Annex III or IV may be applied when their conditions are met, the product falls within their scope, and their expiry dates have not passed. Technical documentation must support the assessment.
Timeline
Exemptions and annexes change
RoHS has applied for years, but substance lists and exemptions change through delegated directives. A previously accepted exemption may expire or narrow in scope, requiring periodic reassessment.
Compliance
The CE marking can be challenged
A product that does not comply with RoHS cannot lawfully be CE marked as conforming. Authorities may require corrective action, withdrawal, or recall. Incorrect supplier declarations do not remove the manufacturer's responsibility.
Action plan
Secure the RoHS evidence
- Confirm product category and scope
- Break the product down into homogeneous materials
- Collect material declarations and test evidence
- Check substance limits and exemptions
- Document the EN IEC 63000 approach where relevant
- Update technical documentation and the EU declaration
Verca
Material evaluation with traceable exemptions
Verca supports structured material declarations, RoHS limits, and review of relevant substance exemptions in the BOM workflow. The customer remains responsible for data quality, testing strategy, and the final conformity decision.