RoHS is a foundational environmental regulation designed to protect human health and the environment by restricting the use of specific hazardous substances in the manufacture of electrical and electronic equipment. Originally established by the European Union (Directive 2002/95/EC), the regulation has evolved significantly.
In the United Kingdom, following our exit from the EU, RoHS compliance is governed by the RoHS Regulations 2012 (as amended). This legislation mirrors the EU’s RoHS 2 (Directive 2011/65/EU) and RoHS 3 (Delegated Directive 2015/863) but is administered under UK law. For businesses, this means navigating the transition from the CE mark to the UKCA (UK Conformity Assessed) marking, ensuring that technical files are robust enough to withstand scrutiny from the Office for Product Safety and Standards (OPSS).
At Enviropass, we simplify this process, providing end-to-end support to ensure your products remain compliant, competitive, and sustainable.
Navigating chemical restrictions requires a blend of regulatory knowledge, supply chain management, and analytical chemistry. Enviropass offers a unique, holistic approach:
| Substance | Threshold Limit | Common Uses in Electronics |
|---|---|---|
| Lead (Pb) | 0.1% (1000 ppm) | Solder, battery terminals, glass in components. |
| Mercury (Hg) | 0.1% (1000 ppm) | Sensors, relays, fluorescent lamps. |
| Cadmium (Cd) | 0.01% (100 ppm) | Pigments, stabilizers in PVC, plating. |
| Hexavalent Chromium (Cr VI) | 0.1% (1000 ppm) | Corrosion-resistant coatings, metallic finishes. |
| Polybrominated Biphenyls (PBB) | 0.1% (1000 ppm) | Flame retardants in plastics. |
| Polybrominated Diphenyl Ethers (PBDE) | 0.1% (1000 ppm) | Flame retardants in circuit boards and housings. |
| Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% (1000 ppm) | Plasticizers in cables and wires. |
| Butyl benzyl phthalate (BBP) | 0.1% (1000 ppm) | Flexible PVC components. |
| Dibutyl phthalate (DBP) | 0.1% (1000 ppm) | Adhesives, coatings, and inks. |
| Diisobutyl phthalate (DIBP) | 0.1% (1000 ppm) | Used as a softening agent in synthetic resins. |
RoHS is specific to Electrical and Electronic Equipment (EEE) and restricts 10 specific substances at the material level. REACH is a much broader regulation that applies to almost all physical products (articles) and chemicals, focusing on the registration and notification of "Substances of Very High Concern" (SVHCs).
No. Batteries are covered by their own specific regulation (The Batteries and Accumulators Regulations). However, the device the battery is inside is subject to RoHS.
RoHS 3 refers to the amendment (EU 2015/863) that added four phthalates (DEHP, BBP, DBP, DIBP) to the original list of six restricted substances. These restrictions have been fully integrated into UK law.
Equipment designed specifically for military purposes or for use in space is generally excluded from the scope of RoHS. However, "dual-use" items may still require compliance.
It is a material that cannot be mechanically disjointed into different materials. Examples include individual types of plastic, metals, alloys, paper, glass, and coatings.
Legally, the manufacturer is responsible. A self-declaration is a good start, but under IEC 63000, you must assess the trustworthiness of that supplier. If they are unknown or in a high-risk region, additional testing is advised.
There is no set expiry date, but you must ensure the report reflects the current version of the law and the current components being used in production. If a supplier changes their material, a new report is needed.
The OPSS can issue fines, require you to recall all products from the market, and in severe cases, pursue criminal prosecution.
For the UK market (Great Britain), the UKCA mark is now the standard. However, the UK government has currently extended the recognition of the CE mark for many products to reduce the burden on businesses. We recommend checking the specific transition dates for your EEE category.
This is the "Environment-Friendly Use Period" label required by China RoHS. It is a circle with a number inside representing the years the product can be used before the hazardous substances might leak out.
Generally, spare parts for the repair or reuse of equipment placed on the market before the restriction applied are exempt to prevent premature obsolescence.
No. Packaging is subject to the Packaging (Essential Requirements) Regulations, which limit lead, cadmium, mercury, and hexavalent chromium to a combined total of 100ppm.
X-Ray Fluorescence (XRF) is a fast, non-destructive way to scan components for heavy metals. It is an excellent "first-pass" screening tool but cannot detect phthalates.
Exemptions are temporary allowances for substances where no reliable alternative exists. For example, Lead in high-melting-temperature solders (Exemption 7a).
There are 11 categories, including Small Household Appliances, IT & Telecoms, and Monitoring & Control Instruments. Our consultants help you classify your product accurately.
Yes, any cable with a rated voltage of less than 250V that connects EEE to a power source or connects two pieces of EEE is in scope.
It is the international standard that specifies the documentation a manufacturer must compile to demonstrate RoHS compliance.
No. You need to demonstrate "due diligence." This usually involves a mix of supplier vetting and periodic "spot check" testing.
Not necessarily. A product could be lead-free but still contain restricted phthalates or flame retardants above the limits.
Cadmium has a much stricter limit of 0.01% (100 ppm), whereas the other nine substances have a limit of 0.1% (1000 ppm).
Yes, this is our core service. We can build your Technical File from scratch or audit your existing documentation for gaps.
No, RoHS only applies to the physical hardware.
Contact Enviropass today with your product description and Bill of Materials. We will provide a bespoke roadmap and quote for your compliance journey.
