What Is RoHS 2.0? Restricted Substances and EU Compliance Requirements Explained

RoHS 2.0 commonly refers to Directive 2011/65/EU, the European Union directive restricting hazardous substances in electrical and electronic equipment. Its purpose is to reduce risks to human health and the environment while supporting safer material use, recycling, and waste management.

The current amended RoHS framework restricts 10 hazardous substances in homogeneous materials. It also incorporates conformity assessment, technical documentation, the EU Declaration of Conformity, and CE marking requirements.

Which Substances Are Restricted under RoHS?

DEHP, BBP, DBP, and DIBP were added to Annex II through Commission Delegated Directive (EU) 2015/863. The amended legislation is sometimes informally called “RoHS 3,” but the underlying legal framework remains Directive 2011/65/EU as amended.

What Is a Homogeneous Material?

RoHS concentration limits are assessed at the homogeneous material level, not by averaging the substance content across an entire finished product.

A homogeneous material has a uniform composition throughout or consists of materials that cannot be mechanically separated into different materials. Examples may include:

• Connector housing resin
• Terminal plating
• Solder material
• Copper conductors
• Cable insulation
• Metal screws or brackets

A finished product may therefore fail RoHS requirements even when its overall average concentration is low, if one individual homogeneous material exceeds the applicable limit.

Which Products Are Covered by RoHS?

RoHS generally applies to electrical and electronic equipment that depends on electric currents or electromagnetic fields to perform at least one intended function and is designed for rated voltages not exceeding:

• 1,000 V AC
• 1,500 V DC

The directive covers a broad range of consumer, industrial, medical, monitoring, communication, lighting, and electronic equipment. Certain products and applications are excluded or subject to specific conditions, so applicability must be assessed according to the finished product, its intended function, and the current legal text.

Connectors, cables, wire harnesses, and components may not always be independently CE-marked under RoHS when supplied solely for incorporation into another product. However, their material composition and supplier documentation directly affect the compliance of the finished equipment.

How Is RoHS Related to CE Marking?

RoHS 2.0 is part of the EU CE-marking framework for applicable electrical and electronic equipment.

Before placing a covered product on the EU market, the manufacturer generally needs to:

• Determine whether RoHS applies
• Identify material and substance risks
• Collect relevant supplier declarations and test information
• Prepare technical documentation
• Complete the applicable conformity assessment
• Issue an EU Declaration of Conformity
• Affix CE marking
• Maintain conformity during production

CE marking represents the manufacturer’s declaration that the product complies with all applicable EU harmonisation legislation, not only RoHS.

What Documentation Is Needed for RoHS Compliance?

RoHS compliance is not established by a single universal certificate. Manufacturers should maintain documentation proportionate to the material and supply-chain risks of the product.

Common records include:

• Bill of Materials (BOM)
• Supplier declarations
• Material composition information
• Third-party laboratory reports
• Component and material specifications
• Risk assessments
• Exemption records
• Change-control documentation
• EU Declaration of Conformity

EN IEC 63000:2018 is the harmonised standard for technical documentation used to assess materials, components, and electrical and electronic equipment for compliance with restricted-substance requirements.

A laboratory report can support compliance, but it does not replace supplier management, traceability, technical documentation, or the manufacturer’s legal responsibility.

Are RoHS Exemptions Available?

Yes. RoHS contains exemptions for specific applications where substitution may not yet be technically or scientifically practicable or where alternatives may create greater environmental, health, or reliability impacts.

Exemptions are mainly listed in Annexes III and IV. Each exemption has a defined scope and may have an expiration or review date. Companies should verify:

• The exact exemption number
• The applicable equipment category
• The permitted application
• The current validity period
• Whether renewal or replacement conditions apply

An exemption that was valid for an earlier project may not remain valid for a new product or production period.

Does RoHS Compliance Require Product Testing?

Not every material or component must automatically undergo full laboratory testing.

A risk-based compliance approach may combine:

• Reliable supplier declarations
• Material specifications
• Manufacturing process knowledge
• Historical test data
• Targeted laboratory testing
• Periodic supplier reviews

Testing is more important when documentation is incomplete, material risks are high, suppliers change, or restricted substances are likely to be present in plating, solder, pigments, flame retardants, or plasticisers.

RoHS vs. REACH, WEEE, and Halogen-Free Requirements

A product that complies with RoHS does not automatically comply with REACH or halogen-free requirements. Similarly, using lead-free solder does not prove compliance with the other nine restricted substances.

Common RoHS Misunderstandings

RoHS compliance means the product contains none of the restricted substances

Not necessarily. The substances may be present below the applicable maximum concentration limits or used under a valid exemption.

A supplier declaration is always sufficient

Not always. The required level of evidence depends on material risk, supplier reliability, product complexity, and regulatory exposure.

One test report covers every future production lot

Not necessarily. Changes to materials, suppliers, plating, resin formulations, manufacturing locations, or processes may require a new compliance assessment.

RoHS and halogen-free mean the same thing

No. RoHS restricts 10 specific substances, while halogen-free requirements normally focus on chlorine and bromine content under separate industry or customer specifications.

Summary

RoHS 2.0 is the EU framework restricting hazardous substances in electrical and electronic equipment. The current amended requirements cover 10 substances, with compliance assessed at the homogeneous material level.

Effective RoHS compliance requires more than obtaining a laboratory report. Manufacturers should manage material selection, supplier documentation, BOM data, exemptions, production changes, technical documentation, and the EU Declaration of Conformity as part of an ongoing compliance system.

Official Regulatory References

European Commission — RoHS Directive

EUR-Lex — Consolidated Directive 2011/65/EU

EUR-Lex — Commission Delegated Directive (EU) 2015/863

European Commission — RoHS Implementation and Exemptions

Technical Support from SyncTronics

SyncTronics provides technical support for reviewing the material and documentation requirements of connectors, cables, wire harnesses, electromechanical components, and electronic interconnect solutions.

Support may include reviewing supplier RoHS declarations, REACH information, halogen-free requirements, material specifications, terminal plating, connector housing materials, cable insulation, and relevant test documentation.

SyncTronics supports High-Mix, Low-Volume electronic interconnect solutions.

For New Product Introduction (NPI), OEM/ODM customization, and wire harness assembly projects, SyncTronics can assist with product selection, specification verification, and supplier-document review. Final responsibility for RoHS applicability, technical documentation, the EU Declaration of Conformity, and CE marking remains with the manufacturer placing the completed product on the market.

Need Wire Harnesses, Connectors, Electromechanical Components, or Custom Solutions? Contact Us Today

Whether you are looking for connectors, cables, wire harness assemblies, electromechanical components, or complete electronic interconnect solutions, SyncTronics provides professional technical support and engineering evaluation for product selection, specification verification, New Product Introduction (NPI), OEM/ODM customization, as well as high-speed transmission, high-reliability, and other specialized application requirements.

We welcome you to visit our Contact Us page and share your project requirements and contact information. Our team is committed to responding quickly and professionally, evaluating the most suitable products and electronic interconnect solutions based on your product specifications, application requirements, and project objectives. We also provide technical recommendations and customized engineering support to help shorten product selection and development time, reduce project risks, and accelerate your path to mass production. We look forward to the opportunity to work with you and provide reliable technical support and practical solutions for every stage of your project.

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This content is compiled based on publicly available information and industry experience, intended solely for reference during technical exchanges. It does not constitute any commercial, technical, or legal advice or basis.

The specifications, materials, manufacturing processes, application methods, and related information described herein may vary due to differing design conditions, environmental factors, or usage scenarios. No guarantees are made regarding the completeness, correctness, or suitability of such content.

Readers should verify the suitability with the responsible design or technical personnel based on actual application scenarios, and independently assess all associated risks.