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EU RoHS 2 (Directive 2011/65/EU)

Little Pro on 2016-01-08

EU RoHS 2 refers to Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (EEE). It replaced the first EU RoHS directive 2002/95/EC (RoHS 1) and entered into force on 21 July 2011.

Like RoHS 1, RoHS 2 restricts the use of certain hazardous substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers) in electrical and electronic equipment (EEE). Compared to RoHS 1, RoHS 2 not only expanded the scope of products covered, but also imposed new obligations on EEE manufacturers to prepare EU declaration of conformity and affix CE markings on finished products.

EU RoHS 2 Restricted Substances

RoHS 2 currently restricts 10 hazardous substances in EEE and they are included in the Annex II of the Directive 2011/65/EU.

Status Substances and Limits
Current Restrictions
  • Cadmium(Cd): 0.01%
  • Mercury: 0.1%
  • Lead(Pb) : 0.1%
  • Hexavalent chromium (Cr6+) : 0.1%
  • Polybrominated biphenyls (PBB): 0.1 %;
  • Polybrominated diphenyl ethers (PBDE): 0.1 %
  • Bis(2-Ethylhexyl) phthalate (DEHP): 0.1% (added in 2015);
  • Benzyl butyl phthalate (BBP): 0.1% (added in 2015);
  • Dibutyl phthalate (DBP): 0.1% (added in 2015);
  • Diisobutyl phthalate (DIBP): 0.1% (added in 2015).

It shall be noted that above maximum concentration values apply to each homogeneous material rather than a product or a part itself. A homogeneous material means material of uniform composition throughout that cannot be mechanically separated into different materials.

Some companies have set stricter limits than above regulatory limits. For example, Apple's limit for Cadmium in homogeneous material is 0.005%.

EU RoHS 2 and Phthalates

DEHP, BBP, DBP and DIBP are primarily used as plasticisers to soften plastics. They will be restricted from 22 July 2019 for all electrical and electronic equipment apart from Category 8 (medical devices) and Category 9 (monitoring and control equipment) that will have an additional two years to comply by 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 REACH Regulation (EC) No 1907/2006. The restriction limits of phthalates in toys under REACH are stricter.

  • Applicable for all children’s toys and childcare articles for children under 3: DEHP+DBP+BBP≤0.1%;
  • Applicable for all children’s toys and child care articles that can be placed in children’s mouth: DINP + DIDP + DNOP≤ 0.1%

Scope of EU RoHS 2 and Exemptions

Annex I of the Directive 2011/65/EU lists 11 categories of EEE covered by RoHS2. It does not only include all EEE covered by RoHS 1, but also includes medical devices, monitoring control instruments and a new category which captures all other "grey area" electrical equipment. Different compliance deadlines have been set for those newly added products.

  • 22 July 2014: Non-industrial control and monitoring instruments and most medical devices;
  • 22 July 2016: In vitro diagnostic medical devices
  • 22 July 2017: Industrial monitoring and control instruments;
  • 22 July 2019: All other EEE, other than those that are specifically excluded.

RoHS 2 Exemptions: Military equipment, large-scale stationary industrial tools, large-scale fixed installations, active implantable medical devices, and photovoltaic panels are excluded from RoHS 2. Batteries and package materials are also out the scope of RoHS since they are subject to different directives. In addition to that, annexes III and IV of RoHS 2 contain certain applications that are exempt from RoHS restrictions (For example, Cadmium in helium-cadmium lasers). Some RoHS 2 exemptions are time limited.

Labelling & CE Marking

RoHS II requires that EEE manufacturers conduct conformity assessment, prepare declarations of conformity, and affix CE markings on finished products to demonstrate compliance. Unlike China, there is no special RoHS 2 marking in Europe. EEE bearing the CE mark is presumed to be in compliance with RoHS 2. The format of the declaration of conformity has been given in Annex VI of the RoHS 2.


EU RoHS is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) Directive 2012/19/EU which sets collection, recycling and recovery targets for electrical and electronic goods. It is also similar to the End of Life Vehicles (ELV) regulation which pushes producers to manufacture new vehicles without hazardous substances (in particular lead, mercury, cadmium and hexavalent chromium).

For electronic and electrical goods placed on EU market, you will see the following two signs on them. The first symbol is CE mark demonstrating compliance with RoHS and other EU directives. The second symbol is the WEEE recycling symbol.

EU RoHS 2 Exemptions

RoHS, Batteries and Packaging Materials

In EU, batteries and packaging materials are out of the scope of EU RoHS 2. However, this might not be true for other countries. More info can be found below:

RoHS in Other Countries

Country Summary & Reference
  • China RoHS 2.0: The Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (Being drafted).
  • Restricts the same 6 hazardous substances as EU RoHS 2.0;
  • Additional RoHS labelling requirements set by SJ/T 11364-2014;
  • More info about China RoHS 2.0.
  • Japan RoHS: JIS C 0950 The marking for presence of the specific chemical substances for electrical and electronic equipment;
  • Applicable to 7 types of electrical and electronic products;
  • Mandatory disclosure and labeling if the content of 6 hazardous substances exceeds certain limits;
  • Read more about Japan RoHS
  • Korea RoHS: The Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles (2007);
  • Korea's version of the RoHS, WEE and ELV directives;
  • Restricts the same 6 hazardous substances as EU RoHS 2.0;
  • Read more about Korea RoHS
  • Taiwan RoHS:CNS 15663 Guidance to reduction of the restricted chemical substances in electrical and electronic equipment;
  • Voluntary national standard restricting the same 6 hazardous substances;
  • Sets its own hazardous substance marking requirement.
  • More info about Taiwan RoHS
  • No federal RoHS-style legislation;
  • California's Electronic Waste Recycling Act of 2003 (EWRA) prohibits the sale of some electronic devices after January 1, 2007, that are prohibited from being sold under the EU RoHS directive;
  • The substances restricted are "certain heavy metals," specifically lead, mercury, cadmium and hexavalent chromium;
  • Reference

Reference & Resources

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 Tags: Topics - RestrictionRoHS