RoHS Directive: Restricted Substances in Electronics and the DPP

RoHS is the EU rule that decides whether an electronic product may enter the market at all. It restricts ten hazardous substances in electrical and electronic equipment, and a product that exceeds the limits cannot legally be sold in the EU — regardless of how good it is otherwise. For anyone preparing an electronics Digital Product Passport, RoHS is the compliance layer that sits at the very front of the product lifecycle.

This article explains what RoHS actually restricts, who has to comply and how, how it differs from REACH and the SCIP database, and where its data overlaps with the Digital Product Passport under the ESPR.

Key takeaways

RoHS (Directive 2011/65/EU, “RoHS 2”) restricts ten hazardous substances in electrical and electronic equipment placed on the EU market.
The threshold is a maximum concentration by weight in each homogeneous material — 0.1% for nine substances and 0.01% for cadmium.
Compliance is demonstrated through an EU Declaration of Conformity, the CE marking and a technical file — RoHS is one of the legal bases for the CE mark on electronics.
Since 22 July 2019 RoHS has an “open scope”: category 11 catches all EEE not otherwise excluded.
RoHS is not REACH or SCIP — it bans specific substances at market entry, while SCIP notifies SVHC substances into an ECHA database at the waste stage.
myDPP does not test products or issue conformity declarations; it stores, versions and communicates the RoHS compliance data and documents attached to a product.

What is the RoHS Directive?

RoHS stands for Restriction of Hazardous Substances. The current version, Directive 2011/65/EU (known as RoHS 2), entered into force on 21 July 2011 and recast the original RoHS 1 directive (2002/95/EC), which had applied from 1 July 2006.

The purpose is straightforward: reduce the amount of hazardous material that ends up in electronics, so that the equipment is safer to use, easier to recycle and less harmful once it becomes waste. RoHS therefore sits directly upstream of the WEEE Directive, which governs the same products once they reach end of life. RoHS keeps the substances out at the start; WEEE deals with what is left at the end.

RoHS is a product-level market rule. It applies to the equipment itself, not to a company’s reporting obligations, and it is enforced through market surveillance: national authorities can test products, demand technical documentation and withdraw non-compliant equipment from sale.

The ten restricted substances and their limits

RoHS 2 restricts ten substances. The limit is a maximum concentration value tolerated by weight in homogeneous materials — meaning each individual material in a product (a solder joint, a cable sheath, a housing) must stay under the threshold, not the product as an average.

Substance	Maximum concentration
Lead (Pb)	0.1%
Mercury (Hg)	0.1%
Cadmium (Cd)	0.01%
Hexavalent chromium (Cr VI)	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 original list held six substances. The four phthalates (DEHP, BBP, DBP, DIBP) were added by Delegated Directive (EU) 2015/863 and applied from 22 July 2019 — and from 22 July 2021 for medical devices and monitoring and control instruments.

Which products are in scope?

RoHS covers electrical and electronic equipment (EEE) across eleven categories: large and small household appliances, IT and telecommunications equipment, consumer equipment, lighting, electrical and electronic tools, toys, leisure and sports equipment, medical devices, monitoring and control instruments, automatic dispensers, and — since the 2019 change — category 11, “other EEE not covered by any of the categories above”.

That eleventh category is what makes RoHS an “open scope” directive since 22 July 2019: if a piece of equipment runs on electric current or electromagnetic fields and is not specifically excluded, it falls under RoHS. Some products remain outside scope (for example large-scale fixed installations, certain military equipment and specific spare parts), but the default assumption for a new electronic product should be that RoHS applies.

Exemptions exist for specific applications where a substitute is not yet technically feasible — for example lead in certain high-melting-temperature solders. These are listed in Annex III (general) and Annex IV (medical devices and monitoring and control instruments). Exemptions are time-limited: they expire and must be renewed, so a product that relies on one needs to track its validity.

How you demonstrate RoHS compliance

RoHS compliance is not certified by an outside body — it is self-declared by the manufacturer on the basis of evidence. The route mirrors the general product-conformity model of EU law:

Assess the materials — gather supplier declarations, material data and, where needed, analytical test results for each homogeneous material.
Compile the technical documentation — the harmonised standard EN IEC 63000 describes how to assemble the technical file for RoHS.
Draw up the EU Declaration of Conformity — a signed statement that the product meets RoHS (usually combined with the declaration for other applicable directives).
Affix the CE marking — RoHS is one of the legal bases behind the CE marking on electronics.

Every economic operator has a role: manufacturers carry the primary duty, importers must verify that the manufacturer has done the work before placing a product on the EU market, and distributors must not supply equipment they know to be non-compliant. This chain of responsibility is exactly the kind of information a product passport can make traceable.

RoHS, REACH and SCIP — three different instruments

These three regimes are often confused because they all deal with substances in products, but they answer different questions:

RoHS bans ten specific substances above a threshold in electrical and electronic equipment, at the moment the product is placed on the market. Exceed the limit and the product cannot be sold.
REACH (Regulation (EC) 1907/2006) governs chemicals broadly. Its Candidate List of Substances of Very High Concern (SVHC) drives duties across all article types — not just electronics.
SCIP is the ECHA database into which producers notify articles containing an SVHC above 0.1% by weight. It is a transparency and waste-management tool, not a ban.

In practice an electronics manufacturer deals with all three: RoHS as a hard market-entry limit, REACH/SCIP as an ongoing notification and communication duty, and WEEE at end of life. Together they form the substance-and-lifecycle chain for electronics.

RoHS and the Digital Product Passport

Under the ESPR (Regulation (EU) 2024/1781), electronics is expected to be among the earlier product groups to carry a Digital Product Passport. The DPP is a data carrier — reached through a QR code or GS1 Digital Link — that presents verified product information to consumers, recyclers and market surveillance authorities.

RoHS data fits naturally into that carrier. Substance-restriction status, the reference to the EU Declaration of Conformity, applicable exemptions and the CE basis are all facts an electronics product already has to hold under RoHS. The DPP is a way to make them verifiable at the product itself, rather than buried in a filing cabinet or a separate compliance system. A market surveillance officer scanning a QR code could confirm the RoHS declaration; a recycler could see which restricted substances were designed out.

To be clear about what this does and does not mean: the DPP does not replace RoHS compliance. You still have to keep the substances below the thresholds, compile the technical file and issue the Declaration of Conformity. The passport carries the evidence — it does not create it.

And to be equally clear about myDPP’s role: myDPP does not perform chemical analysis, does not determine whether a product is RoHS-compliant, and does not issue Declarations of Conformity or affix the CE marking. Those are the manufacturer’s responsibility, supported by testing laboratories where analysis is required. What myDPP does is store, version and communicate the verified compliance data and documents — so the RoHS status travels with the product through its passport.

What companies should do now

Map your products to RoHS scope — with open scope, assume RoHS applies unless a specific exclusion is documented.
Get substance data from your supply chain — supplier declarations and material data per homogeneous material are the foundation of the technical file.
Check your exemptions — if a product relies on an Annex III or IV exemption, track its expiry date.
Keep the documentation current — the technical file, Declaration of Conformity and CE basis must reflect the product as it is actually built.
Structure the data for reuse — the same substance and conformity data feeds RoHS, SCIP, WEEE reporting and, in time, the electronics DPP. Holding it once, in a structured system, avoids maintaining it several times over.

Frequently asked questions (FAQ)

Is RoHS the same as REACH?

No. RoHS restricts ten named substances in electrical and electronic equipment at market entry. REACH is the broad EU chemicals regulation; its SVHC Candidate List and the SCIP notification duty apply to all article types and work differently from RoHS’s hard limits.

Does a product need a certificate to prove RoHS compliance?

There is no mandatory third-party certificate. The manufacturer self-declares compliance through the EU Declaration of Conformity, supported by a technical file (often assembled using EN IEC 63000) and the CE marking.

What does the RoHS threshold actually measure?

It is the maximum concentration by weight in each homogeneous material — the smallest unit of material that could be separated. It is not a product-wide average, so a single non-compliant component can make the whole product non-compliant.

Does the DPP make RoHS obligations easier?

It does not remove them, but it can make the resulting data reusable and verifiable. The substance and conformity data you already need for RoHS can be carried in the electronics DPP, reducing duplicate record-keeping across RoHS, SCIP and WEEE.

Sources

Directive 2011/65/EU (RoHS 2) — EUR-Lex
Delegated Directive (EU) 2015/863 (addition of four phthalates) — EUR-Lex
Harmonised standard EN IEC 63000 (technical documentation for RoHS)
European Commission — RoHS Directive overview
Regulation (EU) 2024/1781 (ESPR) — EUR-Lex