RoHS Compliance: The 10 Restricted Substances and What You Need to Do

If you sell electronics or electrical equipment in the EU, you have very likely heard of RoHS. But do you know exactly which substances are regulated, which threshold values apply, and what you specifically need to do to document your compliance? In this article, we give you the full overview.

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances and is an EU directive that restricts the use of certain hazardous substances in electrical and electronic equipment (EEE). The purpose is to protect human health and the environment — particularly in relation to the waste management of electronics.

RoHS 2 (Directive 2011/65/EU)

The current version, RoHS 2, entered into force in 2013 and replaced the original RoHS Directive from 2006. RoHS 2 significantly expanded the product categories and introduced requirements for CE marking as well as an EU Declaration of Conformity for products falling under the directive. Additionally, requirements were introduced for all actors in the supply chain — not just the manufacturer.

RoHS 3 (Delegated Directive 2015/863/EU)

RoHS 3 is an amendment to RoHS 2 that, from July 2019, expanded the list of restricted substances from 6 to 10 by adding four phthalates. For medical devices and monitoring and control instruments, the new substances applied from July 2021.

The 10 Restricted Substances and Their Threshold Values

Here is the full list of substances restricted under RoHS. All threshold values are given as maximum concentration per homogeneous material by weight:

Note that cadmium has a lower threshold value than the other substances, as it is particularly toxic even in small concentrations. The four phthalates (nos. 7-10) were added with RoHS 3 and have collectively expanded the compliance burden for many manufacturers significantly.

Which Product Categories Are Covered?

RoHS 2 covers 11 product categories of electrical and electronic equipment:

1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer electronics
5. Lighting equipment
6. Electrical and electronic tools
7. Toys, leisure, and sports equipment
8. Medical devices
9. Monitoring and control instruments
10. Automatic dispensers (vending machines, etc.)
11. Other EEE not covered by the above categories

Category 11 is a catch-all category, which in practice means that almost all electrical and electronic equipment is covered. If your product depends on electrical power for at least one of its primary functions, you should assume that RoHS applies.

Exemptions: Annex III and Annex IV

Not all uses of the restricted substances are prohibited. The RoHS Directive contains two important annexes with exemptions:

Annex III contains general exemptions that apply to all product categories. Examples include lead in glass for cathode ray tubes, lead in high-temperature soldering materials (with over 85% lead), and mercury in certain types of fluorescent lamps. These exemptions are granted where there are no technically feasible alternatives.

Annex IV contains specific exemptions for medical devices and monitoring and control instruments. Examples include lead in certain sensors and transducers.

All exemptions have an expiry date and must be renewed. It is your responsibility to stay informed about whether the exemptions you rely on are still valid. The European Commission reviews exemptions on an ongoing basis, and several have already expired or been narrowed.

Supplier Documentation: The Foundation of Your Compliance

Your RoHS compliance is only as strong as your documentation. You must be able to document that every homogeneous material in your product meets the threshold values. In practice, this requires:

• Material declarations from suppliers — your component and material suppliers must provide declarations confirming that their products comply with RoHS. These can be in the form of IPC 1752A forms or similar standard formats.
• Full Material Disclosure (FMD/BOM) — a detailed bill of materials that links material data to each component.
• Traceability — you must be able to trace which material data belongs to which production batches.

It is crucial that you do not just collect the declarations, but also verify them. A supplier declaration is only a starting point — you still bear full responsibility as a manufacturer or importer. Read our guide to the REACH regulation to understand how chemical regulation is interconnected across EU legislation.

Test Methods: XRF Screening and Chemical Analysis

To verify that your products actually meet the threshold values, two primary test methods are used:

XRF Screening (X-ray Fluorescence)

XRF is a fast, non-destructive screening method that can identify the elements in a material. It is well-suited as a first screening step because it:

• Is fast (seconds per measurement)
• Does not destroy the sample
• Can directly measure most of the regulated elements

However, XRF has limitations: it cannot distinguish between hexavalent chromium and other forms of chromium, and it cannot measure phthalates. If the XRF result shows values close to the threshold, further chemical analysis is recommended.

Chemical Analysis

For phthalates and hexavalent chromium, chemical analysis is required — typically GC-MS (gas chromatography-mass spectrometry) for phthalates and UV-Vis spectroscopy or IC (ion chromatography) for hexavalent chromium. These methods are destructive and more expensive but provide precise results.

A practical approach is to use XRF as a screening tool to identify potentially problematic components and then target chemical analysis at the areas where it is needed.

How Conphora Helps You with RoHS Compliance

RoHS compliance involves many data points, suppliers, and ongoing updates. Conphora brings it all together in one place:

• Automatic material validation — upload supplier declarations and material certificates, and the system automatically checks against the 10 RoHS substances and their threshold values.
• Supplier management — keep track of which suppliers have provided documentation and who needs updates.
• Exemption monitoring — get alerted when exemptions in Annex III/IV are approaching expiry, so you can act in time.
• Audit-ready documentation — generate the documentation required by market surveillance authorities with one click.

See Conphora’s automatic validation and experience how the platform removes the manual processes from your RoHS compliance.

See how to organise your compliance documentation, so you are always ready for inspection.

Summary

RoHS is not merely a formality — it is a fundamental requirement for selling electrical and electronic equipment in the EU. With 10 restricted substances, complex exemption lists, and requirements for full traceability across the entire supply chain, it is an area where systematic processes and the right tools make a decisive difference.

Start by mapping your products’ material composition, ensure you have up-to-date supplier documentation, and consider XRF screening as an ongoing control mechanism. With the right approach, RoHS compliance is manageable — and with Conphora, it becomes even easier.

Ready to get your RoHS documentation in order? Conphora gives you a single unified overview of substances, threshold values, and supplier declarations — automatic and always up to date. See pricing and get started →