RoHS GLOSSARY

Annex I of Directive 2011/65/EU lists the ten categories of electrical and electronic equipment (EEE) subject to RoHS restrictions: (1) Large household appliances; (2) Small household appliances; (3) IT and telecommunications equipment; (4) Consumer equipment; (5) Lighting equipment; (6) Electrical and electronic tools; (7) Toys, leisure, and sports equipment; (8) Medical devices; (9) Monitoring and control instruments (including industrial monitoring and control instruments); (10) Automatic dispensers. All EEE placed on the EU market must fall within one of these categories to determine applicable restrictions, exemptions (Annex III or IV), and CE marking obligations.

Annex II of Directive 2011/65/EU lists the ten restricted hazardous substances and their maximum concentration values (MCVs) in homogeneous materials. The ten substances and their MCVs are: Lead (Pb): 0.1% (1000 ppm); Mercury (Hg): 0.1% (1000 ppm); Cadmium (Cd): 0.01% (100 ppm); Hexavalent chromium (Cr⁶⁺): 0.1% (1000 ppm); Polybrominated biphenyls (PBBs): 0.1% (1000 ppm); Polybrominated diphenyl ethers (PBDEs): 0.1% (1000 ppm); Bis(2-ethylhexyl) phthalate (DEHP): 0.1% (1000 ppm); Butyl benzyl phthalate (BBP): 0.1% (1000 ppm); Dibutyl phthalate (DBP): 0.1% (1000 ppm); Diisobutyl phthalate (DIBP): 0.1% (1000 ppm). Directive (EU) 2025/2456 (December 12, 2025) requires the Annex II substance list to be reviewed by ECHA at least once every four years.

Annex III of Directive 2011/65/EU lists specific applications or uses of restricted substances that are exempted from the substance restrictions for all EEE categories in Annex I. Exemptions under Annex III are granted when substitution of a restricted substance is technically or scientifically impracticable, or when the negative impacts on reliability, safety, or environmental impact of substitutes would outweigh the benefits. On July 25, 2025, the EU Commission published an updated comprehensive list of existing, withdrawn, and ongoing Annex III exemptions. On September 8, 2025, delegated directives C(2025)5961 and C(2025)5939 added exemptions for lead in steel, aluminium, copper alloys, and high-melting temperature solders. Each exemption carries an expiry date; manufacturers must monitor renewals. Directive (EU) 2025/2456 transfers exemption application processing from the European Commission to ECHA.

Annex IV of Directive 2011/65/EU lists exemptions from restricted substance restrictions that apply exclusively to medical devices (EEE category 8) and monitoring and control instruments (EEE category 9). Annex IV exemptions exist because these sectors often require long product lifecycles, specific performance characteristics, and safety assurance levels that make substitution of restricted substances particularly difficult. As with Annex III, each Annex IV exemption is time-limited and must be renewed. The EU Commission’s July 25, 2025 list update includes Annex IV exemption status. Directive (EU) 2025/2456 also transfers Annex IV exemption applications to ECHA.

Under RoHS Directive 2011/65/EU Article 3(12), an authorised representative is any natural or legal person established within the EU who has received a written mandate from a manufacturer located outside the EU to act on their behalf in relation to specified obligations. Authorised representatives for RoHS purposes may: draw up the technical file; draw up and sign the Declaration of Conformity; keep the DoC available to national authorities; cooperate with market surveillance authorities; and provide national authorities with all necessary information on the product’s conformity. Non-EU manufacturers may appoint an authorised representative, though it is not mandatory under RoHS (unlike some other EU directives).

Brazil’s RoHS-equivalent regulation is ABNT NBR 16156:2013 (Electrical and Electronic Products — Restriction of the Use of Certain Hazardous Substances), developed by the Brazilian Association of Technical Norms (ABNT). It restricts the same six hazardous substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at equivalent concentration limits. Brazil’s regulatory framework also includes the National Solid Waste Policy (Lei 12.305/2010) and specific sector agreements for EEE, which create extended producer responsibility (EPR) obligations. INMETRO (National Institute of Metrology, Quality, and Technology) oversees conformity assessment for electronics in Brazil.

Cadmium (Cd) is one of the ten restricted hazardous substances under RoHS Directive 2011/65/EU. It is restricted in all EEE at a maximum concentration value of 0.01% (100 ppm) by weight per homogeneous material — the strictest of all RoHS substance limits. Cadmium is used in electroplating, pigments, stabilisers, and certain semiconductor applications. Directive (EU) 2024/1416 (published May 21, 2024) narrowed the exemption for cadmium in LED chips: Annex III entry 39(a) expired November 21, 2025; entry 39(b) was created with a revised, narrower scope for specific remaining applications.

California’s Electronic Waste Recycling Act (CA EWRA, Public Resources Code §42460 et seq.) is a state-level US regulation that restricts certain hazardous substances in covered electronic devices (CEDs) sold in California. The CA EWRA restricts four of the six EU RoHS 1 substances (Pb, Hg, Cd, Cr⁶⁺) at the same concentration limits as EU RoHS in CEDs. Covered devices are primarily video display devices with screens larger than four inches. California operates a state-level e-waste recycling fee system funded through the CEDs advance recycling fee (ARF). California’s ARF is paid at point-of-sale by consumers; manufacturers bear product compliance obligations.

The CE marking (Conformité Européenne) is the mandatory conformity marking indicating that an EEE product complies with applicable EU legislation, including the RoHS Directive 2011/65/EU. Under RoHS Article 7, EEE manufacturers must affix the CE marking before placing products on the EU market. The CE marking under RoHS must appear on the product itself or on its packaging, and must be accompanied by a Declaration of Conformity. For EEE, CE marking also encompasses compliance with other applicable directives (e.g., Low Voltage Directive, EMC Directive).

China RoHS (Management Methods for the Restriction of Hazardous Substances in Electrical and Electronic Products) is China’s national regulation restricting hazardous substances in EEE. The current regulation, Order No. 32 (China RoHS 2), was issued by MIIT (Ministry of Industry and Information Technology) and entered into force January 1, 2016, with full phase-in by July 1, 2019. China RoHS restricts the same six substance groups as EU RoHS (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs), but applies a different concentration limit framework and requires additional labeling: products containing restricted substances above thresholds must display the orange hazardous substances marking; products below thresholds display the green product logo.

A conformity assessment is the process by which a manufacturer evaluates and demonstrates that an EEE product meets the requirements of the RoHS Directive 2011/65/EU before placing it on the EU market. Under RoHS Article 8, the conformity assessment procedure involves: conducting the assessment (material testing, supplier declarations, analysis); compiling the Technical Documentation (per Annex VI or EN IEC 63000:2018); drawing up a Declaration of Conformity (DoC); and affixing the CE marking. Unlike some EU directives, RoHS does not require involvement of a third-party Notified Body — it is a manufacturer self-declaration process.

A Declaration of Conformity (DoC) is the formal written statement in which a manufacturer declares that an EEE product meets all applicable requirements of the RoHS Directive 2011/65/EU (and any other applicable EU directives). Under RoHS Article 13, the DoC must: identify the product; reference the applicable directives and standards used; include the name and address of the manufacturer; be signed by an authorised representative; and confirm the product complies with Annex II substance restrictions and any applicable exemptions. The DoC must be kept and made available to market surveillance authorities for ten years after the product is placed on the market.

Under RoHS Directive 2011/65/EU Article 3(14), a distributor is any natural or legal person in the supply chain (other than the manufacturer or importer) who makes EEE available on the EU market. Distributors have specific RoHS obligations under Article 11: verify that the EEE bears CE marking; check that the manufacturer and importer have fulfilled their documentation obligations; ensure the EEE is accompanied by the required documentation; and not place EEE on the market where they have reason to believe it is not compliant.

The European Chemicals Agency (ECHA) has been formally entrusted with scientific and technical tasks under the RoHS Directive following the adoption of Directive (EU) 2025/2456 (published December 12, 2025). Under this amendment: ECHA is responsible for preparing dossiers for substance restrictions under Annex II; restriction proposals may be prepared by Member States or by ECHA upon Commission request; ECHA processes exemption applications (previously handled by the European Commission); and the Annex II substance list must be reviewed regularly by ECHA, at least once every four years.

Electrical and Electronic Equipment (EEE) is defined in RoHS Directive 2011/65/EU Article 3(1) as equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields, and is designed for use with a voltage rating not exceeding 1000 V for alternating current and 1500 V for direct current. RoHS applies to EEE falling within the product categories in Annex I. Open scope (covering all EEE not explicitly excluded) applies since 22 July 2019 following the phased implementation under Directive 2011/65/EU.

EN IEC 63000:2018 (Technical Documentation for the Assessment of Electrical and Electronic Products with Respect to the Restriction of Hazardous Substances) is the harmonised European standard specifying the technical documentation requirements for RoHS compliance. It defines the content, structure, and evidence requirements for technical documentation used to demonstrate conformity with Directive 2011/65/EU, including: supplier declarations, test reports, material data sheets, risk assessment, and a declaration of compliance. Compliance with EN IEC 63000:2018 gives a presumption of conformity with the RoHS technical documentation requirements.

The Eurasian Economic Union (EAEU) Technical Regulation 037/2016 ‘On Restriction of the Use of Hazardous Substances in Electrical and Electronic Products’ is the RoHS-equivalent regulation for EAEU member states: Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan. TR EAEU 037/2016 entered into force March 1, 2018, and restricts the same six hazardous substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at the same concentration limits. Compliance requires a conformity declaration or certificate of conformity, and products must bear the EAC (Eurasian Conformity) mark.

An exemption under RoHS Directive 2011/65/EU is a specific authorisation for the use of a restricted substance in a defined application or material where substitution is technically or scientifically impracticable, or where the negative environmental, health, or consumer safety impacts of substitutes would outweigh the benefits. Exemptions are listed in Annex III (all EEE categories) and Annex IV (medical devices and monitoring/control instruments only). Under Article 5, exemptions are time-limited and must be renewed. Renewal applications must be submitted at least 18 months before expiry. Following Directive (EU) 2025/2456 (December 12, 2025), exemption applications are submitted to ECHA.

Global RoHS equivalents are national or regional regulations that restrict the same or similar hazardous substances as the EU RoHS Directive in electrical and electronic equipment. Key global RoHS equivalents include: China RoHS (Order No. 32, 2016); UK RoHS (SI 2012/3032, as amended); India E-Waste Management Rules (E-Waste Rules 2022); Japan J-Moss (JIS C 0950:2008); South Korea Resource Recycling Act (RRA, Act No. 18547); Turkey RoHS (AEEE Yönetmeliği); California Electronic Waste Recycling Act (CA EWRA); Saudi Arabia (SASO RoHS); Taiwan (CNS 15663); Ukraine (UkrSEPRO); Brazil (ABINEE/ABNT NBR 16156:2013); and Eurasia/EAEU (Technical Regulation TR EAEU 037/2016).

Hexavalent chromium (Cr⁶⁺, chromium(VI)) is one of the ten restricted hazardous substances under RoHS Directive 2011/65/EU, restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Hexavalent chromium is used in decorative and functional electroplating (e.g., hard chrome plating, chromate conversion coatings on aluminium and zinc), corrosion inhibitors in cooling systems, and pigments. In EEE, it is most commonly found in surface finishes and protective coatings on metal components.

A homogeneous material is defined in RoHS Directive 2011/65/EU Article 3(20) as a material that cannot be mechanically disjointed into different materials — meaning a single material, uniform throughout its composition. RoHS maximum concentration values (MCVs) for restricted substances apply at the homogeneous material level, not at the product or component level. Examples: a plastic pellet, a wire coating, a solder alloy, a plating layer, or a glass substrate. A component such as a capacitor is not a homogeneous material; it must be disaggregated into its constituent homogeneous materials for assessment.

IEC 62321 is the international standard series specifying test methods for determining the concentrations of restricted substances in EEE, developed by IEC Technical Committee 111 (Environmental standardization for electrical and electronic products). The series covers: IEC 62321-1 (Introduction and Overview); IEC 62321-2 (Disassembly, disjointment, and mechanical sample preparation); IEC 62321-3 (Screening for lead, mercury, cadmium, total chromium, total bromine — XRF); IEC 62321-4 (Mercury by CV-AAS, CV-AFS, ICP-OES, ICP-MS); IEC 62321-5 (Cadmium, lead, total chromium by AAS, ICP-OES, ICP-MS); IEC 62321-6 (Polybrominated biphenyls and polybrominated diphenyl ethers by GC-MS); IEC 62321-7-1 (Hexavalent chromium in polymer and electronics by colorimetric method); IEC 62321-7-2 (Hexavalent chromium in solid materials); IEC 62321-8 (Phthalates by GC-MS).

Under RoHS Directive 2011/65/EU Article 3(13), an importer is any natural or legal person established within the EU who places EEE from a third country on the EU market. Importers have significant RoHS obligations under Article 10: ensure the EEE has been subjected to the conformity assessment procedure; ensure the manufacturer has drawn up a Declaration of Conformity; ensure CE marking is affixed; verify the manufacturer’s technical documentation; attach their own name and contact address to the product; and not place non-compliant EEE on the market. Importers must also cooperate with market surveillance authorities and maintain copies of the DoC for ten years.

India’s RoHS-equivalent regulation is contained in the E-Waste (Management) Rules, currently the E-Waste (Management) Rules 2022 issued by the Ministry of Environment, Forest and Climate Change (MoEFCC). Schedule II of the Rules restricts the same six hazardous substances as EU RoHS (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) at the same concentration limits. The Rules apply to manufacturers, producers, importers, and dealers of 21 product categories of EEE listed in Schedule I. Compliance requires Extended Producer Responsibility (EPR) registration with the Central Pollution Control Board (CPCB).

J-Moss (Japanese Industrial Standard JIS C 0950:2008 — ‘Marking for the Presence of the Specific Chemical Substances for Electrical and Electronic Equipment’) is Japan’s RoHS-equivalent marking standard. It applies to seven categories of EEE and six restricted substances (the same six as EU RoHS 1: lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs). J-Moss requires a J-Moss mark to be displayed on products indicating whether restricted substances are present above a threshold. Unlike EU RoHS, J-Moss is a JIS standard (not a law), making it a market expectation rather than a legal mandate in most cases, though it aligns with the Law for the Promotion of Effective Utilization of Resources (LPEUR).

Korea RoHS is implemented through the Act on the Resource Circulation of Electrical and Electronic Equipment and Vehicles (Resource Recycling Act, RRA), Act No. 18547, last amended 2022, administered by the Ministry of Environment (MoE). The RRA restricts the same six hazardous substances as EU RoHS 1 (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) in EEE, at the same concentration limits. Compliance requires: a hazardous substance content label on products; submission of substance content information to the Korea Environmental Industry & Technology Institute (KEITI); and meeting e-waste take-back obligations.

RoHS labeling requirements vary by jurisdiction. Under EU RoHS 2 (Directive 2011/65/EU), no product-level substance content label is required; instead, the CE marking signifies RoHS compliance and is the visible compliance indicator. However, many global RoHS equivalents require explicit substance content labels on products: China RoHS mandates an orange (hazardous substances present above threshold) or green (compliant product) logo; Japan J-Moss requires a J-Moss content mark; Korea RRA requires hazardous substance content labeling; India E-Waste Rules require labeling with hazardous substance presence; and Saudi Arabia SASO RoHS and Taiwan CNS 15663 have specific labeling requirements.

Lead (Pb) is the most commonly regulated restricted substance under RoHS Directive 2011/65/EU, restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Lead was historically used extensively in EEE: as solder (tin-lead alloys), in glass (CRT displays, leaded glass in lamps), in stabilisers for PVC cables, in surface treatments (lead-based paints, coatings), and in batteries. RoHS restricts lead in all EEE categories across Annex I, subject to specific exemptions in Annex III (all categories) and Annex IV (medical devices and monitoring/control instruments). Delegated directives C(2025)5961 and C(2025)5939 (September 8, 2025) updated lead exemptions for steel, aluminium, copper alloys, and high-melting temperature solders.

Under RoHS Directive 2011/65/EU Article 3(11), a manufacturer is any natural or legal person who manufactures EEE, or who has EEE designed or manufactured and markets that EEE under their own name or trademark. Manufacturers have the most comprehensive RoHS obligations under Article 7: design and manufacture EEE in accordance with Annex II restrictions; draw up required technical documentation; conduct the conformity assessment; draw up the Declaration of Conformity; affix CE marking; affix name, registered trademark, and address on the EEE; provide instructions and safety information; take corrective actions when EEE is non-compliant; and cooperate with market surveillance authorities.

Market surveillance is the activity by which competent national authorities in EU Member States verify that EEE placed on the EU market complies with applicable legislation, including RoHS Directive 2011/65/EU. Under Article 19 of RoHS and Regulation (EU) 2019/1020 (Market Surveillance Regulation), national authorities may: inspect products and documentation; require manufacturers, importers, or distributors to provide technical documentation and DoC; conduct or commission substance testing; and order corrective action, market withdrawal, or product recall for non-compliant EEE. RAPEX (now SAFETY Gate) is the EU rapid alert system through which Member States notify each other of dangerous non-compliant products.

Maximum concentration values (MCVs) are the substance-specific concentration limits above which a restricted substance is prohibited in a homogeneous material under RoHS Directive 2011/65/EU. The MCVs in Annex II are: 0.1% (1000 mg/kg or 1000 ppm) for lead (Pb), mercury (Hg), hexavalent chromium (Cr⁶⁺), PBBs, PBDEs, DEHP, BBP, DBP, and DIBP; and 0.01% (100 mg/kg or 100 ppm) for cadmium (Cd). These limits apply per homogeneous material within the EEE, not per product or component. MCVs are not equivalent to maximum impurity levels — homogeneous materials containing restricted substances above the MCV must either use an applicable exemption or be eliminated from the product.

Mercury (Hg) is one of the ten restricted hazardous substances under RoHS Directive 2011/65/EU, restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Mercury was historically used in fluorescent lamps (compact fluorescent lamps — CFLs), mercury-containing switches and relays, and measuring instruments. Several Annex III exemptions exist for mercury in specific lamp types and measuring instruments where substitution is technically difficult. The transition to LED lighting has significantly reduced mercury use in consumer lighting EEE, though certain professional lighting and measuring instrument exemptions remain active.

Polybrominated biphenyls (PBBs) are a group of brominated flame retardants historically used in plastics for EEE. PBBs are restricted under RoHS Directive 2011/65/EU at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. PBBs were phased out of most EEE applications before the introduction of RoHS due to environmental and health concerns. The primary concern is their persistence, bioaccumulation potential, and toxicity (PBT properties). PBBs are assessed together with PBDEs in RoHS technical documentation.

Polybrominated diphenyl ethers (PBDEs) are a group of brominated flame retardants used in plastics, printed circuit boards, and textile applications in EEE. PBDEs are restricted under RoHS Directive 2011/65/EU at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. Ten individual congener groups include decabromodiphenyl ether (DecaBDE), octaBDE, and pentaBDE. DecaBDE was subject to debate but is now also restricted following alignment with Stockholm Convention obligations and REACH restrictions. PBDEs are assessed using IEC 62321-6.

Four phthalate plasticisers were added to the RoHS restricted substances list by Directive 2015/863/EU, amending Annex II: bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP). All four are restricted at a maximum concentration value of 0.1% (1000 ppm) by weight per homogeneous material. They apply to EEE categories 1–7 and 10 from July 22, 2019; categories 8, 9, and 11 (medical devices, monitoring instruments, in vitro diagnostics) from July 22, 2021. The four phthalates are used as plasticisers in PVC and other polymers to make them flexible.

Quantum dots are semiconductor nanocrystals used in display technologies (QLED displays, photoluminescent films in LCDs) to enhance colour accuracy and efficiency. Cadmium selenide (CdSe) quantum dots contain cadmium, a restricted substance under RoHS Annex II at 0.01% (100 ppm) per homogeneous material. Annex III entry 39(a) provided an exemption for cadmium in quantum dots for LED chips, which expired November 21, 2025 following Directive (EU) 2024/1416 (published May 21, 2024). Directive (EU) 2024/1416 created a revised, narrower-scope exemption entry 39(b) covering specific remaining quantum dot applications that cannot yet be replaced with cadmium-free alternatives.

Directive (EU) 2024/232 addresses the use of recycled PVC (polyvinyl chloride) containing lead and/or cadmium in EEE. Historically, recycled PVC may contain residual lead or cadmium from legacy stabilisers, presenting challenges for circular economy practices under RoHS. Directive (EU) 2024/232 allows continued use of recycled PVC containing lead or cadmium in specific EEE applications (primarily window and door profiles and structural applications in smart home/building automation EEE) under stricter conditions than the original exemptions, to support the circular economy while maintaining environmental protection. Specific quantity limits, material tracking, and supply chain transparency requirements apply.

RoHS 2 refers to Directive 2011/65/EU of the European Parliament and of the Council on the restriction of the use of certain hazardous substances in electrical and electronic equipment, adopted June 8, 2011 and effective from January 2, 2013. RoHS 2 recast and replaced RoHS 1, introducing: expanded product scope (open scope covering all EEE by July 2019); CE marking and Declaration of Conformity requirements; responsibilities for manufacturers, importers, distributors, and authorised representatives; technical documentation requirements; and a pathway for adding new restricted substances (Article 6). Four phthalates were added via Directive 2015/863/EU. Directive (EU) 2025/2456 (December 12, 2025) transferred scientific and technical tasks to ECHA.

RoHS 3 is the informal designation for Directive (EU) 2015/863, which amended Annex II of Directive 2011/65/EU (RoHS 2) to add four phthalate plasticisers to the list of restricted substances: DEHP, BBP, DBP, and DIBP. These substances were added following their identification as substances of very high concern (SVHC) under REACH and their subsequent restriction under Annex XVII of REACH. The four phthalates apply at a maximum concentration value of 0.1% (1000 ppm) per homogeneous material from July 22, 2019 for most EEE categories (July 22, 2021 for medical devices and monitoring/control instruments).

'RoHS 4' is an informal industry term referring to potential future amendments to Directive 2011/65/EU that may add new restricted substances or further revise the regulatory framework. No formal legislative proposal for ‘RoHS 4’ has been adopted as of April 2026. Substances under consideration for potential future restriction include: Tetrabromobisphenol A (TBBPA), a flame retardant, and Medium Chain Chlorinated Paraffins (MCCPs). These are under review as part of the EU Chemicals Strategy for Sustainability. The transfer of tasks to ECHA (Directive (EU) 2025/2456, December 2025) streamlines the pathway for future substance additions to Annex II.

The scope of EU RoHS Directive 2011/65/EU is defined in Article 2. It applies to EEE falling within the categories of Annex I, cables and spare parts for repair and reuse, and accessories. The open scope (since July 22, 2019) covers all EEE not explicitly excluded. Article 2(4) excludes specific items from RoHS scope, including: equipment for military and security purposes; space equipment; large-scale stationary industrial tools; large-scale fixed installations; means of transport for persons or goods (excluding electric two-wheel vehicles); non-road mobile machinery for professional use; active implantable medical devices; photovoltaic panels; equipment for research and development only.

Saudi Arabia’s RoHS-equivalent regulation is managed by the Saudi Standards, Metrology and Quality Organization (SASO). Products placed on the Saudi market may be subject to SASO’s technical regulations restricting hazardous substances in EEE, broadly aligned with EU RoHS. Products covered by SASO’s mandatory product conformity programme (SALEEM programme) — which includes many EEE categories — must obtain SASO conformity certificates. SASO’s technical regulations for EEE substance restrictions align with the six original RoHS substances (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) and applicable EU/IEC standards.

Lead-free soldering refers to the use of solder alloys that do not contain lead (Pb) above the RoHS Annex II maximum concentration value of 0.1% (1000 ppm). The transition from tin-lead (SnPb) solders to lead-free solders was one of the most significant manufacturing changes driven by RoHS 1 (2006). The most widely used lead-free solder alloys are SAC (tin-silver-copper) alloys, particularly SAC305 (96.5% Sn, 3% Ag, 0.5% Cu). Lead-free soldering requires higher process temperatures than SnPb soldering (melting point ~220°C for SAC305 vs. ~183°C for SnPb), which has implications for component heat tolerance and PCB design.

Substance restriction under RoHS refers to the prohibition of restricted hazardous substances in homogeneous materials above maximum concentration values (MCVs) per Annex II of Directive 2011/65/EU. Under Article 6, the Commission may amend Annex II to add new substances following a review and assessment of available evidence. Directive (EU) 2025/2456 (December 12, 2025) significantly changes the process: ECHA is now formally entrusted with preparing restriction dossiers; restriction proposals may be prepared by Member States or by ECHA on Commission request; and Annex II must be reviewed at least once every four years.

A supplier declaration (also called a material declaration or substance declaration) is a written statement from a component or material supplier confirming the substance content of their supplied material or component relative to RoHS restricted substances. Under EN IEC 63000:2018, supplier declarations are the primary evidence mechanism for demonstrating RoHS compliance, particularly for substances in homogeneous materials that cannot be practically tested at the receiving manufacturer’s level. Declarations must specify: which substances are present; their concentration per homogeneous material; reference to the applicable standard; and the signatory’s name and date.

Taiwan RoHS is implemented through the Regulations for Restricted Use of Certain Hazardous Substances in Electrical and Electronic Equipment, aligned with CNS 15663 (Chinese National Standard). Administered by the Bureau of Standards, Metrology and Inspection (BSMI) and Ministry of Economic Affairs, it restricts the same six hazardous substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at equivalent concentration limits, in a broad range of EEE product categories. Taiwan RoHS requires a conformity mark on products and an accessible content declaration table on the product or its packaging, similar to China’s labeling approach.

Technical documentation under RoHS Directive 2011/65/EU is the body of evidence compiled by manufacturers to demonstrate product conformity with all applicable RoHS requirements. Under Article 8 and Annex VI, the technical documentation must include: a general description of the EEE; design and manufacturing drawings; list of harmonised standards applied; results of design calculations and inspections; test reports; a Declaration of Conformity; and, under EN IEC 63000:2018, supplier declarations, materials declarations, and risk assessment for restricted substances. Technical documentation must be kept for ten years from the date the product is placed on the market.

UK RoHS refers to the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (SI 2012/3032) and its amendments, which implement RoHS requirements for Great Britain (England, Scotland, and Wales) following Brexit. UK RoHS is substantially equivalent to EU RoHS 2 (Directive 2011/65/EU), including the same ten restricted substances, MCVs, exemptions, CE marking equivalent (UKCA marking from January 2025 for most products), technical documentation, and DoC requirements. However, UK RoHS exemptions are updated separately from EU exemptions and may diverge over time. Northern Ireland is subject to EU RoHS under the Windsor Framework.

Ukraine has implemented RoHS-equivalent requirements through its Technical Regulation on Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment, adopted to align with EU RoHS as part of Ukraine’s EU Association Agreement obligations. The regulation restricts the same substances as EU RoHS 1 (Pb, Hg, Cd, Cr⁶⁺, PBBs, PBDEs) at equivalent concentration limits, with a product certification and conformity marking system (previously UkrSEPRO). Ukraine’s ongoing EU integration process under the Association Agreement is progressing towards further harmonisation with EU product regulations, including RoHS 2.

X-ray fluorescence (XRF) is an analytical technique used for non-destructive screening of elemental content in materials. Under IEC 62321-3-1 (portable XRF) and IEC 62321-3-2 (laboratory XRF), XRF is the primary screening method for detecting lead (Pb), mercury (Hg), cadmium (Cd), total chromium (Cr — cannot distinguish hexavalent from trivalent), and total bromine (Br — cannot distinguish PBBs from PBDEs or other brominated compounds) in EEE components and materials. XRF is rapid, non-destructive, and cost-effective, making it the first-pass compliance screening tool across supply chains. It cannot detect phthalates (organic compounds) or hexavalent chromium specifically.