RoHS 4 (Future Development)

'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.

European Commission Chemicals Strategy for Sustainability; Directive (EU) 2025/2456 (December 12, 2025); ECHA substance restriction dossier preparations.

Manufacturers should monitor ECHA’s preparation of restriction dossiers for TBBPA and MCCPs, as these substances are used in flame-retardant plastics and polymers in EEE. The ECHA-led process introduced by Directive (EU) 2025/2456 may accelerate the timeline for adding new substances to Annex II. Industry associations should engage actively in the public consultation process when restriction proposals are published. Proactive substitution of substances under consideration can reduce future compliance burden.