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EXPERTISE · ROHS

RoHS

Restricting hazardous substances in electrical and electronic equipment, in Great Britain and the EU.

Restricting hazardous substances in electrical and electronic equipment.

RoHS (the Restriction of Hazardous Substances) restricts the use of ten hazardous substances in electrical and electronic equipment (EEE). In Great Britain the requirements are set out in UK RoHS and enforced by the Office for Product Safety and Standards (OPSS); the equivalent EU regime is Directive 2011/65/EU, commonly known as RoHS 2. The two regimes currently share the same restricted substances and concentration limits.
For most manufacturers, importers and distributors of EEE, RoHS runs alongside REACH, CLP and other material regulations rather than instead of them — the same product can carry restricted-substance obligations under RoHS and separate registration or classification duties under other regimes at the same time.
✓Restricted substance screening for electrical and electronic equipment
✓Technical documentation and conformity assessment support
✓Alignment with REACH, CLP and wider material compliance
✓Practical, evidence-based compliance positions
RESTRICTED SUBSTANCES

Ten substances, two concentration thresholds.

RoHS sets a maximum concentration value for each restricted substance, measured by weight in any homogeneous material within the product. Cadmium is held to a tighter limit than the other nine. The four phthalates (DEHP, BBP, DBP, DIBP) were added to the original six substances by a later amendment, and now sit alongside them.

Lead (Pb)
Max 0.1% by weight
Mercury (Hg)
Max 0.1% by weight
Cadmium (Cd)
Max 0.01% by weight
Hexavalent chromium (Cr⁶⁺)
Max 0.1% by weight
Polybrominated biphenyls (PBB)
Max 0.1% by weight
Polybrominated diphenyl ethers (PBDE)
Max 0.1% by weight
Bis(2-ethylhexyl) phthalate (DEHP)
Max 0.1% by weight
Butyl benzyl phthalate (BBP)
Max 0.1% by weight
Dibutyl phthalate (DBP)
Max 0.1% by weight
Diisobutyl phthalate (DIBP)
Max 0.1% by weight
SCOPE, EXEMPTIONS & MARKING

What’s in scope, what’s excluded, and how it’s marked.

RoHS applies to EEE falling within eleven equipment categories, from large household appliances and IT equipment through to medical devices, monitoring and control instruments, and a general catch-all category for other electrical and electronic equipment. Military equipment, large fixed installations and large-scale stationary industrial tools sit outside the regulation’s scope, along with a defined list of specific exemptions for substances and applications where a safer substitute is not yet technically or scientifically feasible.

Products in scope need technical documentation demonstrating compliance and a Declaration of Conformity, and in Great Britain must carry either a UKCA or CE mark. The UK currently recognises CE marking indefinitely for RoHS-covered goods alongside UKCA, so businesses can choose either route for the GB market — though the correct route still needs to be confirmed for the specific product and market.

✓11 equipment categories under RoHS 2, and where a given product sits
✓Exemption assessment for restricted substances that cannot yet be substituted
✓UKCA / CE marking route selection for the GB and EU markets
✓Technical documentation and Declaration of Conformity support
ROLES & RESPONSIBILITIES

Your RoHS duties depend on your role in the supply chain.

The same piece of equipment can sit under different duties depending on whether you manufacture it, import it, distribute it, or act as a manufacturer’s authorised representative. We help establish your role for each product line and what it means in practice.

Manufacturer
You design or manufacture EEE, or have it designed or manufactured, and place it on the market under your own name. You carry the primary duty to ensure compliance, carry out conformity assessment and draw up the technical documentation.
Importer
You place EEE from outside Great Britain or the EU on the relevant market. You must verify that the manufacturer has met their obligations and that documentation is available, and ensure the product carries the correct marking.
Distributor
You make EEE available on the market without altering it. You are obliged to check that products carry the required conformity marking and documentation, and to act on any non-compliance information from the manufacturer or importer.
Authorised representative
You are a UK- or EU-based entity given a written mandate to act on a manufacturer’s behalf for specified compliance tasks, such as holding documentation or acting as the contact point for authorities.
DEFENCE & IMPORT CONSIDERATIONS

Applying RoHS with defence-specific rigour.

RoHS carries particular nuance for organisations working in or supplying the defence sector. Getting the position right means more than checking a product against the restricted substance list — it means being able to show how that position was reached, and defending it under scrutiny.

Exemption identification and evidence
Annex III and IV set out specific substance and application exemptions where a safer substitute is not yet technically or scientifically feasible — several of which are used routinely in defence electronics and legacy platforms. We help identify which exemptions genuinely apply to a given product, build the technical justification behind that position, and keep it current as exemptions are periodically reviewed and can be withdrawn.
Threshold testing and reporting
Compliance depends on knowing the actual concentration of each restricted substance in every homogeneous material within a product, not assuming it. We help organisations put a proportionate testing and reporting regime in place — covering supplier declarations, analytical testing where it is genuinely needed, and a documented trail showing how each threshold position was reached and evidenced.
Dual-use and specific military-use determinations
Equipment designed exclusively for military purposes falls outside RoHS scope, but dual-use equipment — used in both civilian and military contexts — generally does not qualify for that exclusion and remains subject to RoHS in its civilian application. We help organisations work through that distinction product by product, and build a defensible, recorded rationale for the decision reached, rather than relying on assumption.
Import responsibilities and team education
Importers carry specific duties under RoHS: confirming the manufacturer has met their obligations, ensuring correct marking and identification information travels with the product, and keeping a Declaration of Conformity available to market surveillance authorities. We help organisations understand where import responsibilities sit within their own supply chain, and build practical guidance so procurement and logistics teams know what to record and retain at the point of import.
HOW WE HELP

Bringing RoHS into a single compliance picture.

Restricted-substance screening for RoHS rarely happens in isolation. The same bill of materials that needs checking against the RoHS substance list often needs checking against REACH’s Candidate List, CLP classification, and any relevant defence or industry-specific material standards at the same time.
We help manufacturers, importers and distributors build a RoHS compliance position that sits inside that wider picture: screening materials and components against the restricted substance list, building the technical documentation a Declaration of Conformity depends on, and keeping the position current as products, suppliers and exemptions change.
✓Bill-of-materials screening against the RoHS restricted substance list
✓Technical documentation and Declaration of Conformity support
✓Exemption tracking as products, suppliers and exemptions change
✓Alignment with REACH, CLP and defence material standards
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