/resources/image/template/step.png ROHS



The Restriction of Hazardous Substances (RoHS) Directive 2002/95/EC, (RoHS 1), short for Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment, was adopted in February 2003 by the European Union.

The RoHS 1 directive took effect on 1 July 2006, and is required to be enforced and become law in each member state. This directive restricts (with exceptions) the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment. It is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC which sets collection, recycling and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic e-waste.


Each European Union member state will adopt its own enforcement and implementation policies using the directive as a guide.

RoHS is often referred to (inaccurately) as the 'lead-free directive', but it restricts the use of the following six substances:

  1. Lead (Pb)
  2. Mercury (Hg)
  3. Cadmium (Cd)
  4. Hexavalent chromium (Cr6+)
  5. Polybrominated biphenyls (PBB)
  6. Polybrominated diphenyl ether (PBDE)

PBB and PBDE are flame retardants used in several plastics. Hexavalent chromium is used in chrome plating, chromate coatings and primers, and in chromic acid.

The maximum permitted concentrations in non-exempt products are 0.1% or 1000 ppm (except for cadmium, which is limited to 0.01% or 100 ppm) by weight. The restrictions are on each homogeneous material in the product, which means that the limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could (theoretically) be separated mechanically—for example, the sheath on a cable or the tinning on a component lead.

As an example, a radio is composed of a case, screws, washers, a circuit board, speakers, etc. The screws, washers, and case may each be made of homogenous materials, but the other components comprise multiple sub-components of many different types of material. For instance, a circuit board is composed of a bare PCB, ICs, resistors, capacitors, switches, etc. A switch is composed of a case, a lever, a spring, contacts, pins, etc., each of which may be made of different materials. A contact might be composed of a copper strip with a surface coating. A speaker is composed of a permanent magnet, copper wire, paper, etc.

Everything that can be identified as a homogeneous material must meet the limit. So if it turns out that the case was made of plastic with 2,300 ppm (0.23%) PBB used as a flame retardant, then the entire radio would fail the requirements of the directive.

In an effort to close RoHS 1 loopholes, in May 2006 the European Commission was asked to review two currently excluded product categories (monitoring and control equipment, and medical devices) for future inclusion in the products that must fall into RoHS compliance. In addition the commission entertains requests for deadline extensions or for exclusions by substance categories, substance location or weight. New legislation was published in the official journal in July, 2011 which supersedes this exemption.

Note that batteries are not included within the scope of RoHS. However, in Europe, batteries are under the European Commission's 1991 Battery Directive (91/157/EEC), which was recently increased in scope and approved in the form of the new battery directive, version 2003/0282 COD, which will be official when submitted to and published in the EU's Official Journal. While the first Battery Directive addressed possible trade barrier issues brought about by disparate European member states' implementation, the new directive more explicitly highlights improving and protecting the environment from the negative effects of the waste contained in batteries. It also contains a program for more ambitious recycling of industrial, automotive, and consumer batteries, gradually increasing the rate of manufacturer-provided collection sites to 45% by 2016. It also sets limits of 5 ppm mercury and 20 ppm cadmium to batteries except those used in medical, emergency, or portable power-tool devices. Though not setting quantitative limits on quantities of lead, lead-acid, nickel, and nickel-cadmium in batteries, it cites a need to restrict these substances and provide for recycling up to 75% of batteries with these substances. There are also provisions for marking the batteries with symbols in regard to metal content and recycling collection information.

The directive applies to equipment as defined by a section of the WEEE directive. The following numeric categories apply:

  1. Large household appliances.
  2. Small household appliances.
  3. IT & Telecommunications equipment (although infrastructure equipment is exempt in some countries)
  4. Consumer equipment.
  5. Lighting equipment—including light bulbs.
  6. Electronic and electrical tools.
  7. Toys, leisure, and sports equipment.
  8. Medical devices (exemption removed in July 2011)
  9. Monitoring and control instruments (exemption removed in July 2011)
  10. Automatic dispensers.
  11. Semiconductor devices

It does not apply to fixed industrial plant and tools. Compliance is the responsibility of the company that puts the product on the market, as defined in the Directive; components and sub-assemblies are not responsible for product compliance. Of course, given the fact that the regulation is applied at the homogeneous material level, data on substance concentrations needs to be transferred through the supply chain to the final producer. An IPC standard has recently been developed and published to facilitate this data exchange, IPC-1752. It is enabled through two PDF forms that are free to use.

RoHS applies to these products in the EU whether made within the EU or imported. Certain exemptions apply, and these are updated on occasion by the EU.

Examples of product components containing restricted substances

RoHS restricted substances have been used in a broad array of consumer electronics products. Examples of leaded components include:

  • paints and pigments
  • PVC (vinyl) cables as a stabilizer (e.g., power cords, USB cables)
  • solders
  • printed circuit board finishes, leads, internal and external interconnects
  • glass in television and photographic products (e.g., CRT television screens and camera lenses)
  • metal parts
  • lamps and bulbs
  • batteries

Cadmium is found in many of the above components; examples include plastic pigmentation, nickel-cadmium (NiCd) batteries and CdS photocells (used in night lights). Mercury is used in lighting applications and automotive switches; examples include fluorescent lamps (used in laptops for backlighting) and mercury tilt switches (these are rarely used nowadays). Hexavalent chromium is used for metal finishes to prevent corrosion. Polybrominated biphenyls and biphenyl Ethers/Oxides are used primarily as flame retardants.

Hazardous materials and the high-tech trash problem

RoHS and other efforts to reduce hazardous materials in electronics are motivated in part to address the global issue of consumer electronics waste. As newer technology arrives at an ever increasing rate, consumers are discarding their obsolete products sooner than ever. This waste ends up in landfills and in countries like China to be "recycled."

Changing toxicity perceptions

In addition to the high-tech trash problem, RoHS reflects contemporary research over the past 50 years in biological toxicology that acknowledges the long-term effects of low-level chemical exposure on populations. New testing is capable of detecting much smaller concentrations of environmental toxicants. Researchers are associating these exposures with neurological, developmental, and reproductive changes.

RoHS and other environmental laws are in contrast to historical and contemporary law that seek to address only acute toxicology, that is direct exposure to large amounts of toxic substances causing severe injury or death.

Life-cycle impact assessment of lead-free solder

The United States Environmental Protection Agency (EPA) has published a life-cycle assessment (LCA) of the environmental impacts of lead-free and tin-lead solder, as used in electronic products. For bar solders, when only lead-free solders were considered, the tin/copper alternative had the lowest (best) scores. For paste solders, bismuth/tin/silver had the lowest impact scores among the lead-free alternatives in every category except non-renewable resource consumption. For both paste and bar solders, all of the lead-free solder alternatives had a lower (better) LCA score in toxicity categories than tin/lead solder. This is primarily due to the toxicity of lead, and the amount of lead that leaches from printed wiring board assemblies, as determined by the leach ability study conducted by the partnership. The study results are providing the industry with an objective analysis of the life-cycle environmental impacts of leading candidate alternative lead-free solders, allowing industry to consider environmental concerns along with the traditionally evaluated parameters of cost and performance. This assessment is also allowing industry to redirect efforts toward products and processes that reduce solders' environmental footprint, including energy consumption, releases of toxic chemicals, and potential risks to human health and the environment. Another life-cycle assessment by IKP, University of Stuttgart, shows similar results to those of the EPA study.

Life-cycle impact assessment of BFR-free plastics

The ban on concentrations of brominated flame retardants (BFR) above 0.1% in plastics has had an impact on plastics recycling. As more and more products include recycled plastics, it has become critical to know the BFR concentration in these plastics, either by tracing the origins of the recycled plastics to establish the BFR concentrations, or by measuring the BFR concentrations from samples. Plastics with high BFR concentrations are costly to handle or to discard, whereas plastics with levels below 0.1% have value as recyclable materials.

There are a number of analytical techniques for the rapid measurement of BFR concentrations. X-ray fluorescence spectroscopy can confirm the presence of bromine (Br), but it does not indicate the BFR concentration or specific molecule. Ion attachment mass spectrometry (IAMS) can be used to measure BFR concentrations in plastics. The BFR ban has had significant impacts both upstream — plastic material selection — and downstream — plastic material recycling.

2011/65/EU (RoHS 2)

The RoHS 2 directive (2011/65/EU) is an evolution of the original directive and became law on 21 July 2011 and took effect 2 January 2013. It addresses the same substances as the original directive while improving regulatory conditions and legal clarity. It requires periodic reevaluations that facilitate gradual broadening of its requirements to cover additional electronic and electrical equipment, cables and spare parts. The CE logo now indicates compliance and RoHS 2 declaration of conformity is now detailed.

In 2012, a final report from the European Commission revealed that some EU Member States considered all toys under the scope of the primary RoHS 1 Directive 2002/95/EC, irrespective of whether their primary or secondary functions were using electric currents or electromagnetic fields. From the implementation of RoHS 2 or RoHS Recast Directive 2011/65/EU on, all the concerned Member States will have to comply with the new regulation.

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