RoHS: does it reach your equipment, and what do you owe?

Who it applies to

Makers, authorised representatives, importers and distributors of electrical and electronic equipment up to 1 000 V AC or 1 500 V DC, unless an Article 2(4) exclusion covers it.

The dates

Now, in all 11 Annex I categories: the last, other EEE, came in on 22 July 2019.

The one thing to do

A manufacturer keeps the technical documentation and the EU declaration of conformity 10 years and affixes the CE marking. Importers and distributors check that it did.

The 10 restricted substances

Annex II as amended, with the maximum concentration by weight each may reach in a homogeneous material. The wording is the Directive's.

• 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 restriction of DEHP, BBP, DBP and DIBP shall apply to medical devices, including in vitro medical devices, and monitoring and control instruments, including industrial monitoring and control instruments, from 22 July 2021.
• The restriction of DEHP, BBP, DBP and DIBP shall not apply to cables or spare parts for the repair, the reuse, the updating of functionalities or upgrading of capacity of EEE placed on the market before 22 July 2019, and of medical devices, including in vitro medical devices, and monitoring and control instruments, including industrial monitoring and control instruments, placed on the market before 22 July 2021.
• The restriction of DEHP, BBP and DBP shall not apply to toys which are already subject to the restriction of DEHP, BBP and DBP through entry 51 of Annex XVII to Regulation (EC) No 1907/2006.

Who carries which article

A directive, through each Member State's law

Directive 2011/65/EU binds through the law each Member State adopted to transpose it, and the authorities that enforce it are national. The table names each state's act, as it notified it to the Commission, read on 18 October 2026.

Every measure each state notified, on EUR-Lex

Read from Directive 2011/65/EU in the Official Journal on 17 October 2026: the consolidated text of 1 July 2026, with its corrections checked and every amending act reviewed. EUR-Lex

Questions people ask

Does RoHS apply to software or a cloud service?

No. It restricts substances in equipment, and software or a service run on someone else's equipment holds no material for Annex II to limit. The equipment it runs on is another matter.

What is a homogeneous material?

Article 3(20): one material of uniform composition throughout, or a combination that cannot be separated by mechanical actions such as unscrewing, cutting or grinding. The Annex II limits apply to each one, not to the product as a whole.

How long do we keep the documents?

A manufacturer keeps the technical documentation and the EU declaration of conformity 10 years after the equipment is placed on the market, Article 7(d). An importer keeps a copy of the declaration as long, Article 9(g).

What is an Annex III or IV exemption?

A specific use of a restricted substance that the Directive allows for a limited time, Article 5. A renewal is applied for no later than 18 months before it expires, Article 5(5); from 13 August 2027, applications go to ECHA.

Where does the CE marking go?

On the finished equipment or its data plate, visibly, legibly and indelibly, before it is placed on the market, Article 15. Where the equipment does not allow that, on the packaging and the accompanying documents.

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