EU RoHS Directive (Restriction of Hazardous Substances, Scope, and Exemptions)
ENFORCEMENT TIMELINE
In force since 2006 (current Directive 2011/65/EU)
Overview
The EU RoHS Directive (Restriction of Hazardous Substances) restricts the use of specific hazardous substances in electrical and electronic equipment.
Because the list of restricted substances and the scope of exemptions are reviewed periodically, companies must maintain ongoing product compliance management.
Enforcement Timeline
July 1, 2006: The original RoHS Directive (RoHS1) takes full effect, triggering a global supply chain shift, including the transition to lead-free solder.
2011: The amended RoHS Directive (RoHS2) is adopted, extending scope to medical devices and monitoring and control instruments, and making the CE marking and preparation of a declaration of conformity a full legal requirement.
July 22, 2019: Restrictions on four phthalates (DEHP, BBP, DBP, and DIBP) take full effect, commonly referred to as the "RoHS 10 substances."
As of October 2026: The Directive still restricts ten substances (European Commission RoHS page). Adding MCCPs and TBBP-A was considered, but no amendment to Annex II has been adopted.
Related Regulations / Topics
EU RoHS Directive: Review of Exemptions for Four Phthalates (DEHP, BBP, DBP, DIBP), 2025–2026
The EU RoHS Directive (2011/65/EU) limits the combined content of four phthalates — DEHP, BBP, DBP, and DIBP — in electrical and electronic equipment (EEE) to 0.1% by weight each. As alternative technologies for rubber and resin parts, wire insulation, and adhesives have matured, the European Chemicals Agency (ECHA) is now reviewing several exemptions previously granted for medical devices and specific industrial equipment, working toward their technical evaluation and eventual expiry.
EU RoHS Directive: Review of Exemptions
Exemptions set out in Annexes III and IV of the EU RoHS Directive (2011/65/EU) permit continued use of certain restricted substances only where no viable alternative technology exists. These exemptions are periodically reviewed and are progressively narrowed or allowed to expire once substitutes become technically feasible. As part of its ongoing evaluation and revision process, the European Commission is transferring the scientific and technical assessment of exemptions to the European Chemicals Agency (ECHA), tightening scrutiny and improving transparency.
EU RoHS Directive: Review and Addition of Restricted Substances
The EU RoHS Directive (2011/65/EU) currently restricts ten hazardous substances in electrical and electronic equipment (EEE) — lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP. Under Article 6, the European Commission periodically reviews candidates for addition to the restricted substances list. Adding medium-chain chlorinated paraffins (MCCPs) and tetrabromobisphenol A (TBBP-A) has been considered, but no amendment to Annex II has been adopted, and the list still contains ten substances (as of October 2026).
EU RoHS Directive: Consideration of Adding Medium-Chain Chlorinated Paraffins (MCCPs) and Tetrabromobisphenol A (TBBP-A) to Restricted Substances
This card covers the consideration of adding medium-chain chlorinated paraffins (MCCPs) and tetrabromobisphenol A (TBBP-A) to Annex II of the EU RoHS Directive (2011/65/EU). No amendment to Annex II has been adopted, and the Directive still restricts ten substances (European Commission RoHS page, as of October 2026). MCCPs (chlorinated paraffins with carbon chain lengths of C14–C17) are widely used as flame-retardant plasticizers in PVC, rubber, adhesives, and cutting oils, while TBBP-A is widely used as a flame retardant in the epoxy resin of printed wiring boards (PWBs). Both substances raise concerns over environmental persistence and toxicity, and the restriction as considered would, in principle, have prohibited content above 0.1% by weight for both.
EU RoHS Directive: Technical Review of Lead-in-Solder Exemptions (7a, 7c-I, and Others) Following Transfer to ECHA
Among the RoHS Directive's exemptions, the two most widely relied upon by electrical, electronic, automotive, and industrial equipment manufacturers are "lead in high-melting-temperature solder" (Exemption 7a) and "lead in glass or ceramic matrix compounds" (Exemptions 7c-I and related entries). Following the transfer of scientific evaluation to the European Chemicals Agency (ECHA), industry consortia (including JEITA and others) have submitted renewal applications, and ECHA is now developing a rigorous roadmap for narrowing, reducing, or phasing out specific use cases, based on assessments of the maturity of alternative technologies such as high-silver solder, nano-copper bonding, and transient liquid phase sintering (TLPS).
Business Impact
Companies supplying electrical and electronic equipment to the EU market — including semiconductor and electronic component manufacturers, and makers of home appliances, medical devices, and automobiles — must build a system for managing restricted substance content. In practice, this means confirming compliance with the current list of restricted substances, collecting content information from suppliers, maintaining bill-of-materials (BOM) records and retaining technical documentation for ten years, keeping CE marking declarations of conformity up to date, and managing exempted uses and their expiration dates. Adding medium-chain chlorinated paraffins (MCCPs) and the brominated flame retardant TBBP-A was considered, but no amendment to Annex II has been adopted, and ten substances remain restricted (as of October 2026).
RoHS compliance requires sharing restricted-substance content information at the component and material level, which in turn requires building industry information-exchange schemes such as IPC-1752 or chemSHERPA, requesting and auditing non-use declarations from suppliers, and aligning compliance processes with related regulations such as REACH — all requiring continuous information management across the entire supply chain.