A Starter Guide to 2020 RoHS Compliance

March 13, 2020 by Tyler Charboneau

What does it take to get the RoHS stamp of approval?

The proliferation of electronic waste has sparked growing environmental concerns in the past 17 years. Manufacturers must curb these impacts while cutting hazardous materials usage from their products.  

The European Commission (EC) enacted the Restriction of Hazardous Substances directive in 2003—effective across the European Union (EU). Abbreviated RoHS (pronounced "ross"), the policy’s goals, according to the official RoHS FAQ page, are as follows: 

  • Reduce the buildup of environmentally-harmful waste in landfills
  • Protect manufacturing workers and recyclers from potential poisoning
  • Achieve these goals by restricting specific metals and compounds

RoHS has since been expanded with the introduction of RoHS 2 in 2011, followed by RoHS 3 in 2015. The EC typically adds more substances to the blacklist with each iteration or expands which electronics are covered under the law. Manufacturers who abide by these laws are “RoHS compliant.”


Who Is Affected by RoHS?

It might appear that only EU manufacturers are affected, but RoHS casts a wider net. Even companies outside of the EU are held accountable. According to the RoHS Guide:

“Any business that sells or distributes applicable EEE products, sub-assemblies, components, or cables directly to EU countries, or sells to resellers, distributors or integrators that in turn sell products to EU countries, is impacted if they utilize any of the restricted materials.”



RoHS is in place to reduce the buildup of harmful e-waste in landfills.

All companies hoping to penetrate the European market must comply with these hazard guidelines. Many of them already are by default. Foreign laws and regulations independent of RoHS have brought companies up to speed. 

In a broad sense, RoHS applies to the electrical and electronic products (EEE) industry and the metal industry. Plating, anodizing, and finishing, and cremating applications are included. 

Consumers are also affected. Companies must provide recycling or disposal procedures to customers, who then send in their discarded devices. This cuts down on unnecessary waste. 


What Materials Does RoHS Restrict?

Hazardous materials restrictions have evolved over time. Here are some commonly-controlled substances:

  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd) 
  • Hexavalent chromium (CrVI)
  • Polybrominated biphenyls (PBBs)
  • Polybrominated biphenyl ethers (PBDEs)

RoHS 3 added phthalate restrictions. These are plasticizers that add flexibility to industrial plastics:

  • DEHP
  • BBP
  • DBP
  • DIBP

Lead interestingly has some exemptions for a few more years. These exemptions apply to the concentration of lead in certain alloys and certain applications. Every substance with restrictions cannot exceed a certain concentration in parts per million (ppm). These quantities are capped at 1,000 ppm with the exception of cadmium’s 100 ppm. 

On the hardware side, RoHS 2 added all electronic and electrical equipment to the coverage. This includes spare parts and cables. Manufacturers were required to meet these requirements by July 22, 2019. 

Older products predating 2006 are not grandfathered in—meaning modifications are needed to get them to current specifications. Companies must update products if they wish to manufacture them further, according to Chris Carragher, director of communications of Enviance.


How Are Manufacturers Responding? 

Many manufacturers offer recycling programs to mitigate e-waste. Apple and competing device manufacturers offer these across their product lineups. This includes trade-ins. Compact devices are replaced (and broken) often, so they must go to the right place. Apple has thoroughly documented its restricted substances policies

Texas Instruments aims to produce as many products as possible that don’t require RoHS exemptions—especially those related to lead. The company works to renew any expiring exemptions where applicable. They also provide an extensive library of compliance documentation related to RoHS and toxic substances

Major semiconductor manufacturers like STMicroelectronics publicize their compliance


ST's sustainable technology program

ST's sustainable technology program. Image used courtesy of STMicroelectronics

All companies with a major electrical foothold must ensure all products comply with EU standards if they wish to remain competitive in the market. 


How Can Your Company Become RoHS Compliant?

To meet RoHS standards, you must undergo four steps: 

  1. Testing—on-site or remotely, via XRF or lab equipment
  2. Process auditing—ensuring all manufacturing adheres to restrictions and guidelines on-site
  3. Documentation review—companies submit technical assessments of materials, drawings, test reports, and compliance certificates. A technical file is required. 
  4. Certification statement—an RoHS certificate of compliance is issued. 


Supplemental Programs

A sister directive to RoHS is Waste from Electrical and Electronic Equipment (WEEE). This program determines how companies treat, recover, and recycle electronics. RoHS reveals that ninety-percent of these components ultimately end up in landfills. Products that meet WEEE standards are adorned by the “Wheelie Bin” sticker.


Wheelie bin sticker.

Wheelie bin sticker. Image used courtesy of the European Commission

The certification mark (CE) may not be awarded to a product if it doesn’t comply with RoHS 2 and or later RoHS iterations. Certified products adhere to sets of health, safety, and environmental standards. These products don’t have to be produced in Europe, either. The mark applies to items sold within the European economic area. 


The Future of RoHS

A common question one might ask is, “Will RoHS change in the future?”

It’s highly likely that we’ll see new updates to RoHS as time passes and discoveries are made. Workplace safety is continually evaluated and substance toxicity assessment is an evolving science. Lawmakers are actively pushing for the study of seven additional substances, which may have potentially harmful effects. As such, they may be added to the RoHS directive in the near future. 

These seven substances under evaluation are: 

  1. Beryllium
  2. Cobalt (dichloride and sulphate)
  3. Diantimony trioxide
  4. Indium phosphide
  5. Medium-Chain Chlorinated Paraffins (MCCPs)
  6. Nickel (sulphate and sulfamate)
  7. Tetrabromobisphenol A (TBBP-A).

The European Commission hopes these requirements will steer us toward a healthier workforce and planet sooner rather than later.