By Deepa ShettyPublished: 3 min read

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Let’s be honest: post-Brexit compliance isn’t just messy — it’s risky. If you’re placing electronic products in the UK market and think CE marking alone keeps you safe, think again.

UK RoHS - officially the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 — is its own regime now. It mirrors the EU RoHS Directive in substance, but the rules of the game have changed.

Here’s what you need to know to stay compliant, avoid fines, and keep your supply chain flowing smoothly.

What Is the UK RoHS Regulation?

The UK RoHS Regulation governs the restriction of ten hazardous substances in electrical and electronic equipment (EEE). While derived from the EU’s framework, it’s now enforced separately by the Office for Product Safety and Standards (OPSS) in Great Britain (England, Scotland, and Wales).

Products sold in Northern Ireland follow EU RoHS under the Windsor Framework and require CE marking. Great Britain (England, Scotland, and Wales) is governed by UK RoHS, where manufacturers can demonstrate conformity with either the UKCA mark or the CE mark. Both are indefinitely accepted for RoHS-scope EEE following the Product Safety and Metrology etc. (Amendment) Regulations 2024.

Scope: Who and What Falls Under UK RoHS?

Applicable to:

  • All finished EEE placed on the GB market

Not applicable to:

  • Components not sold individually to the market
  • Military and space equipment
  • Large-scale fixed installations and stationary industrial tools

You must:

  • Maintain a technical file (including risk assessment and supplier docs)
  • Issue a Declaration of Conformity (DoC)
  • Apply appropriate marking (UKCA or CE)

Managing UK RoHS obligations across a multi-supplier BOM, especially with dual-mark (UKCA/CE) documentation requirements for manufacturers selling into both GB and the EU typically requires structured RoHS compliance software rather than manual tracking.

UK RoHS Restricted Substances and Limits (by weight in homogeneous material)

Under the UK RoHS Regulations (Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment), the following 10 substances are restricted by weight in homogeneous materials. These limits are consistent with EU RoHS requirements.

UK RoHS Restricted Substances and Maximum Concentration Values.PNG

> If you’re over these thresholds in any homogeneous material, your product is non-compliant. No exceptions.

UKCA and CE Marking, What's the Deal?

GB Market: Use the UKCA mark NI Market: Use the CE mark (EU RoHS still applies)

The Product Safety and Metrology etc. (Amendment) Regulations 2024, made on 23 May 2024 and in force from 1 October 2024, removed the previous 31 December 2024 expiry date for CE marking recognition and extended it indefinitely for 21 product regulations, including RoHS. As of 2026, the UK government has not announced any date at which the CE marking will lose its current legal status. Manufacturers placing electrical and electronic equipment on the GB market can choose either the UKCA mark or the CE mark to demonstrate RoHS conformity. UKCA is not mandatory and CE is not a transitional concession — both are accepted on an ongoing basis.

Note: while indefinite, this is a policy decision, not a legal guarantee of permanent status. The government has committed to a minimum two-year transition period if the policy is ever reversed, so CE-only manufacturers have some warning but should still consider commercial exposure to a future reversal.

UK RoHS Technical Documentation: Your First Line of Defense

To prove compliance, your technical file must include:

  • Product design and manufacturing details
  • Material declarations and test reports
  • Risk assessments
  • Supplier certifications
  • DoC with product and issuer details

Pro tip: Maintain this documentation for 10 years post-placement.

Roles and Responsibilities Under UK RoHS

Manufacturers must:

  • Ensure compliance and affix proper markings
  • Create and retain technical docs and DoC

Importers must:

  • Verify manufacturer compliance before import
  • Maintain access to DoC and documentation

Distributors must:

  • Check for proper labeling and documentation
  • Refrain from placing non-compliant products on the market
  • Assume full manufacturer responsibilities if modifying products

UK RoHS Enforcement and Penalties

If you're found non-compliant, OPSS can issue product recalls, corrective action notices, and prosecute manufacturers, importers, or distributors. On summary conviction, historical maximum fines were £5,000, later £20,000; following the Legal Aid, Sentencing and Punishment of Offenders Act 2012 (Section 85, in force 12 March 2015), maximum fines on summary conviction in magistrates' courts in England and Wales for most environmental and product safety offences became unlimited. On conviction on indictment, fines are also unlimited, and offences may carry imprisonment. The "£20,000 maximum" figure is now outdated for most enforcement pathways.

Conclusion: UK RoHS Isn’t Optional, It’s Strategic

If you want to keep selling in the UK, compliance isn’t just a box to check. It’s a core part of your go-to-market strategy.

UK RoHS = market access + brand trust + futureproofing.

Let Regilient Simplify Your UK RoHS Compliance

Tired of chasing certificates or emailing suppliers endlessly? Regilient helps you:

  • Centralize RoHS data across suppliers
  • Auto-generate UKCA-ready DoCs
  • Track risk by BOM or component
  • Prepare for OPSS audits with confidence

Chasing supplier certificates across two separate marking regimes is not a sustainable compliance strategy.

Learn more about Regilient's RoHS compliance software, or book a demo today to turn compliance from chaos into competitive edge.

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UK RoHS Regulation : A Guide for Manufacturers, Importers, and Distributors

What is UK RoHS and how does it differ from EU RoHS?
UK RoHS is Great Britain's own version of the Restriction of Hazardous Substances regulation, covering England, Scotland, and Wales. It restricts the same 10 substances as EU RoHS at the same thresholds, but it is enforced separately by the Office for Product Safety and Standards and requires the UKCA mark rather than the CE mark. The substance rules are effectively identical. What has changed is the marking scheme, the enforcing authority, and the fact that GB now operates entirely outside the EU's regulatory and market surveillance system.
Who must comply with UK RoHS requirements?
Any business placing electrical or electronic equipment on the GB market must comply, including manufacturers, importers, and distributors. Non-UK companies selling into Great Britain are fully in scope regardless of where they are based, and importers specifically must verify manufacturer compliance before goods enter the country.
What substances does UK RoHS restrict and at what limits?
UK RoHS restricts 10 substances, each measured at the homogeneous material level: Lead, mercury, hexavalent chromium, PBB, and PBDE: 0.1% by weight Cadmium: 0.01% by weight Four phthalates (DEHP, BBP, DBP, DIBP): 0.1% by weight each If a product exceeds these thresholds in any homogeneous material, it is non-compliant, with no exceptions based on averaging across the whole product.
Does UK RoHS apply in Northern Ireland?
No. Northern Ireland continues to follow EU RoHS under the Northern Ireland Protocol. Products sold in Northern Ireland must meet EU requirements and carry the CE mark, not UKCA, even when manufactured in Great Britain. This creates a genuinely split compliance landscape within the same country, and manufacturers selling across both GB and NI markets need separate marking strategies for each.
What documentation is required to demonstrate UK RoHS compliance?
A compliant technical file must include product design and manufacturing details, material declarations and test reports, risk assessments, supplier certifications, and a signed Declaration of Conformity. This documentation must be retained for at least 10 years after the product is placed on the market and must be available on request during an OPSS audit.
What penalties apply for UK RoHS non-compliance?
The Office for Product Safety and Standards can order product withdrawals, recalls, and corrective actions for non-compliant goods. Financial penalties can reach up to £20,000 per offence, and in severe cases, criminal prosecution is possible. Non-compliance also risks losing GB market access altogether, which is frequently a more damaging consequence than the fine itself.