| EU law | Directive 2011/65/EU (RoHS 2), as amended. Commission Delegated Directive (EU) 2015/863 added four phthalates to Annex II |
| GB law | The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (SI 2012/3032), as amended |
| Northern Ireland | The 2012 Regulations have a separate NI version that applies Annex II of the EU Directive as amended from time to time. NI follows the EU exemptions system |
| Enforcement (UK) | Office for Product Safety and Standards (OPSS) |
| Scope | All electrical and electronic equipment (EEE), cables and spare parts, unless excluded |
| Related pages | REACH and UK REACH, UKCA and CE marking, WEEE |
What it covers
RoHS restricts the use of certain hazardous substances in electrical and electronic equipment (EEE) placed on the market. EEE is equipment that depends on electric currents or electromagnetic fields to work properly, or that generates, transfers or measures such currents and fields, and is designed for a voltage rating of not more than 1000 V AC or 1500 V DC.
There are 11 categories. Category 3 is IT and telecommunications equipment. Category 11 is other EEE not covered by any other category. EEE that was outside the scope of the earlier RoHS Directive (2002/95/EC) came into scope from 22 July 2019.
Restricted substances and limits
Maximum concentration values are by weight in homogeneous materials. A homogeneous material is one material of uniform composition throughout, or a combination of materials that cannot be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. The Commission FAQ gives the copper wire inside a cable as an example.
| Substance | Maximum concentration |
|---|---|
| Lead | 0.1 % |
| Mercury | 0.1 % |
| Cadmium | 0.01 % |
| Hexavalent chromium | 0.1 % |
| Polybrominated biphenyls (PBB) | 0.1 % |
| Polybrominated diphenyl ethers (PBDE) | 0.1 % |
| Bis(2-ethylhexyl) phthalate (DEHP) | 0.1 % |
| Butyl benzyl phthalate (BBP) | 0.1 % |
| Dibutyl phthalate (DBP) | 0.1 % |
| Diisobutyl phthalate (DIBP) | 0.1 % |
The four phthalates were added by Delegated Directive (EU) 2015/863. They apply from 22 July 2019, and to medical devices and monitoring and control instruments from 22 July 2021. The phthalate restriction does not apply to cables or spare parts for the repair, reuse, updating or upgrading of EEE placed on the market before 22 July 2019.
How cables are treated
For RoHS, cables are defined as all cables with a rated voltage of less than 250 V that serve as a connection or an extension to connect EEE to the electrical outlet, or to connect two or more items of EEE to each other. The European Commission RoHS 2 FAQ (12 December 2012) says:
- Cables used for the transfer of electrical currents or electromagnetic fields are EEE.
- Optical cables are not EEE and therefore not in scope of RoHS 2.
- Specialised cables such as HDMI and network cables, used for example in voice, data and video transfer, are in categories 3 or 4.
- Non-finished cables, such as cable reels without plugs, were outside RoHS 1 and can be classified as category 11.
- Internal wires are not cables. They must meet the substance restrictions as part of the EEE, with no separate CE marking or declaration.
- External cables sold with, or shipped for use with, an item of EEE must meet the restrictions. They need no separate CE marking or declaration if covered by the declaration for that EEE and the EEE is CE marked.
Conformity, documentation and marking
RoHS conformity is self-declared using internal production control (Module A). The manufacturer must:
- draw up technical documentation and carry out internal production control
- draw up a declaration of conformity (EU declaration of conformity for the EU and NI)
- affix the UKCA or CE marking visibly, legibly and indelibly to the product or its data plate, or to the packaging and accompanying documents where that is not possible
- keep the technical documentation and declaration for 10 years after the EEE is placed on the market
- mark a type, batch or serial number, and the manufacturer’s name, registered trade name or trade mark and a single contact address
- keep a register of non-conforming EEE and recalls
Exemptions
Exemptions allow a restricted substance above the limit in a specific application. They are granted for a substance in an application, not for a company or a whole product. EU exemptions are listed in Annexes III and IV of the Directive. GB exemptions are listed in Tables 1 and 2 of Schedule A2 of the 2012 Regulations.
GB runs its own exemptions system, independent of the EU system, and applications must be made separately. Under GB guidance an exemption is valid for 5 years for categories 1 to 7, 10 and 11, and 7 years for categories 8 and 9. Exemption lists in GB and the EU can therefore differ over time.
Great Britain: CE recognition and UKCA
Regulation 34A, substituted on 1 October 2024 by the Product Safety and Metrology etc. (Amendment) Regulations 2024, lets EEE that meets the EU Directive, carries the CE marking and has an EU declaration in English satisfy the GB requirements on technical documentation, conformity assessment, the declaration of conformity and marking. The substance restrictions and exemptions in Schedules A1 and A2 still apply. Until 31 December 2027 the UKCA marking may be placed on a label or accompanying document.
What it means in practice
- Under the Commission FAQ, external cables placed on the market separately, such as network cables, must meet the substance restrictions and need their own declaration of conformity and CE marking.