RoHS Compliance: Obligations, Limits and Verification

Anyone importing electronics or electrical devices from the Far East cannot avoid RoHS. The directive restricts hazardous substances in exactly these products, and responsibility for compliance lies with the importer, not the manufacturer abroad. A missing piece of evidence can stop an entire shipment long before it reaches the warehouse.

In brief: RoHS stands for "Restriction of Hazardous Substances" and limits ten hazardous substances in electrical and electronic equipment. The legal basis is Directive 2011/65/EU, extended by four plasticisers. Compliance is part of CE marking. Importers must ensure that substance limits are met, that test evidence exists, and that the declaration of conformity covers RoHS compliance.

What does RoHS mean?

RoHS is the English abbreviation for "Restriction of Hazardous Substances". The directive prohibits the use of certain heavy metals and flame retardants above defined limits in electrical and electronic equipment. The aim is to protect people and the environment across the entire lifecycle of a device, from production to disposal.

The current version is Directive 2011/65/EU, often called RoHS 2. It was extended by Delegated Directive 2015/863 to add four plasticisers, commonly referred to as RoHS 3. For importers, RoHS is therefore not a one-off topic but a requirement that keeps evolving.

RoHS complements the WEEE Directive on the take-back and disposal of electrical equipment: while WEEE governs a device's end of life, RoHS acts as early as manufacturing and stops hazardous substances from entering circulation in the first place. RoHS 2 tightened conformity assessment in 2011 and folded RoHS firmly into the CE system. The European Commission is also required to review the substance list and exemptions on an ongoing basis, so the legal framework keeps developing.

Which substances does RoHS restrict?

RoHS restricts ten substances whose share per homogeneous material must not exceed a fixed limit. For nine substances the limit is 0.1 percent by weight; for cadmium it is 0.01 percent. What counts is the assessment per material, not per whole device.

The concept of the homogeneous material is the core of the test. A solder joint, a cable insulation, or a coating is each assessed individually. A device can therefore look harmless on average and still breach the limit at a single component.

Which products does RoHS cover?

RoHS covers electrical and electronic equipment, meaning everything that needs electric current or electromagnetic fields to operate. Since the scope was opened up, the directive applies via an open catch-all category to practically all electrical devices, unless there is an explicit exemption. The exact scope and the applicable exemptions are documented by the European Commission.

Typical affected products are household appliances, IT and telecommunications equipment, lighting, tools, toys with electronics, and measuring and control instruments. For buyers, this means: as soon as a product contains a circuit board, a battery, a cable, or a light, the RoHS question belongs on the checklist. You already know this logic from the CE system, because RoHS is one of the building blocks that feed into CE marking.

What exemptions exist from RoHS?

Not every use of a restricted substance is automatically banned. RoHS lists specific uses in Annex III and Annex IV that are exempted because a technical substitute is not yet available or the device's reliability would otherwise suffer. Annex III covers general uses, such as certain lead-based solders in high-temperature applications or mercury in specific lamp types. Annex IV applies exclusively to medical devices and monitoring and control instruments, which were initially exempted from the restriction for longer but are now also being phased in gradually.

What matters for buyers: an exemption only applies to the exact use described and is time-limited. On behalf of the European Commission, the Öko-Institut continuously reviews whether existing exemptions are renewed, narrowed, or revoked. A supplier invoking an exemption should always be able to name the exact annex number and expiry date, not just claim in general terms that their product is "exempted". If an exemption expires without an approved renewal, the standard limit applies again to the affected component from that point on.

What is the difference between RoHS and REACH?

RoHS and REACH are often confused but regulate different things. RoHS restricts ten specific substances in electrical devices; REACH is the much broader chemicals regulation that applies to almost all articles. An imported electrical device usually has to meet both sets of requirements.

In practice, buyers often ask only for a RoHS certificate and overlook that REACH applies in parallel. We regularly see plastic parts and cables that are RoHS-compliant but contain substances of very high concern under REACH. Anyone who queries only one of the two rules has not fully secured the supply chain. That is why we always require both pieces of evidence from suppliers together.

How is RoHS compliance tested technically?

In practice, testing runs in two stages. The first stage uses X-ray fluorescence analysis (XRF): a non-destructive screening method that shows the concentration of lead, mercury, cadmium, chromium, and bromine within seconds and can be applied directly at the manufacturer's site or during incoming goods inspection. If a reading sits close to the limit, or a result needs to be documented in a legally robust way, wet-chemical analysis via ICP-OES or ICP-MS follows, delivering exact concentrations per homogeneous material.

That reference unit is exactly what makes testing laborious: a cable has to be taken apart into insulation, strands, and connector before measurement, since each part counts as its own homogeneous material. Test reports only carry weight when they come from a laboratory accredited to ISO/IEC 17025 that performs quantitative confirmation on top of the initial screening. A manufacturer's self-declaration without a lab report does not substitute for this evidence.

In our incoming goods inspection, we run XRF screening as a standard first step before releasing any batch. If a component flags during screening, we send that specific batch for wet-chemical confirmation testing rather than relying on a single test report from the manufacturer.

What obligations do importers have for RoHS?

Importers must actively ensure RoHS compliance, not merely trust the manufacturer's assurances. You may only place a device on the market if the substance limits are met and the corresponding evidence is available. This obligation is closely interlinked with CE marking, because RoHS is covered by the same EU declaration of conformity.

In our sourcing projects across the Far East, we have RoHS compliance evidenced by test reports from accredited laboratories, not by a mere self-declaration from the manufacturer. For critical components, we additionally run our own material tests before a series is released. The early test costs little, whereas a recall over lead content in a solder joint costs a great deal.

What does China RoHS mean?

China RoHS is a separate Chinese framework and is not identical to the EU directive. It uses similar substance restrictions but has its own labelling and evidence requirements. A product that meets China RoHS is therefore not automatically EU RoHS-compliant.

On labelling, China RoHS runs its own system: products free of restricted substances carry a green "e" symbol, while products containing substances above the limits carry an orange symbol with the so-called Environmental Friendly Use Period (EFUP), a number of years stating how long the component won't leak hazardous substances under normal use. Whether a product additionally needs third-party testing or only a self-declaration with supporting technical documentation depends on the Compliance Management Catalogue maintained by China's Ministry of Industry and Information Technology (MIIT), which keeps expanding to cover more product groups.

This distinction is decisive for importers. Suppliers sometimes point to Chinese conformity when European evidence is required. For import into the EU, only compliance under 2011/65/EU counts. Anyone sourcing from the Far East should clarify this point early, as our guide to importing from China to Germany also shows.

What happens without RoHS compliance?

Without RoHS compliance, an affected device may not be sold in the EU. Market surveillance can prohibit distribution, order a recall, and impose fines. For imports, this regularly hits the importer who placed the goods on the market.

In Germany, the Elektro- und Elektronikgerätestoff-Verordnung (ElektroStoffV) transposes the RoHS directive into national law. Under § 14 ElektroStoffV in conjunction with the Product Safety Act, violations count as administrative offenses and can carry a fine of up to €100,000 per violation, independent of any recall and the reputational damage that comes with it.

Such objections often surface only during an official inspection or in incoming goods inspection. A structured incoming goods inspection with sampling and document checks is therefore the second safeguard, after conformity has been evidenced with the manufacturer. RoHS thus fits into the wider import regulations for 2026, which require an unbroken chain of evidence. Its proximity to other substance-related rules such as the EUDR deforestation regulation shows that compliance increasingly has to be thought through across the entire supply chain.

Frequently asked questions about RoHS compliance

What does RoHS mean? RoHS stands for "Restriction of Hazardous Substances" and limits ten hazardous substances in electrical and electronic equipment above fixed thresholds.

Is RoHS the same as REACH? No. RoHS concerns specific substances in electrical devices; REACH is the general chemicals regulation for almost all articles. Electrical devices must meet both.

Which products does RoHS cover? Electrical and electronic equipment, from household appliances through IT and lighting to tools and electronic toys. An open catch-all category captures almost all electrical devices.

Is China RoHS the same as EU RoHS? No. China RoHS is a separate framework with its own evidence requirements. For import into the EU, only compliance under 2011/65/EU counts.

Who is liable for RoHS compliance on import? The importer. They must obtain the test evidence, secure the documentation, and evidence compliance via the CE declaration of conformity.

Conclusion: anchoring RoHS compliance as a fixed check in purchasing

For importers, RoHS compliance is not a label that the supplier delivers along with the goods, but an obligation of their own with clear limits and hard consequences. Anyone who knows which substances are affected, which products RoHS covers, and how it relates to REACH prevents sales bans and protects their own brand from recalls.

As a sourcing partner, we anchor this check firmly in the purchasing process. We obtain test reports from accredited laboratories, request RoHS and REACH evidence together, and have critical components tested before a series is released. A complex substance requirement becomes a predictable, documented part of your supply chain.

👉 Do you import electronics or electrical devices from the Far East and want to evidence RoHS compliance reliably? Arrange a no-obligation consultation and we will review your products together.