What US manufacturers need to know about RoHS restrictions
Restriction of Hazardous Substances (RoHS) is an EU directive that restricts the use of 10 hazardous materials in electrical and electronic equipment (EEE) sold within the European Union. Adopted in 2003 and in effect since July 1, 2006, the directive aims to protect human health and the environment from the risks these materials pose, both during a product’s use and after disposal.
If you’re a US manufacturer offering EEE products or components that end up in EU hands, even through a distributor rather than a direct sale, RoHS compliance applies to you.
What RoHS Actually Restricts
RoHS restricts the use of ten substances above a threshold of 1,000 ppm (100 ppm for cadmium):
- Lead
- Cadmium
- Mercury
- Hexavalent chromium
- Polybrominated biphenyls (PBB)
- Polybrominated diphenyl ethers (PBDE)
- Bis (2-ethylhexyl) phthalate (DEHP)
- Butyl benzyl phthalate (BBP)
- Dibutyl phthalate (DBP)
- Di-isobutyl phthalate (DIBP)
The first six substances were covered under the original 2006 directive (commonly called RoHS 1). The 2011 recast (RoHS 2, Directive 2011/65/EU) tightened scope and compliance procedures without changing the substance list. The four phthalates were added later, under RoHS 3 (Directive (EU) 2015/863), published in 2015 with enforcement beginning in July 2019.
RoHS vs. REACH: Two Different Regulations
These two get confused often enough that it’s worth separating them clearly. RoHS restricts ten specific substances in electrical and electronic equipment by design, it’s a product-category rule. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is much broader: it covers nearly all chemical substances manufactured or imported into the EU, across every industry, not just electronics, and maintains its own separate list of Substances of Very High Concern (SVHC).
A product can be fully RoHS compliant and still carry REACH obligations, since REACH applies independently of whether a substance happens to also appear on RoHS’s list. Manufacturers selling into the EU generally need to account for both.
What Happens If You’re Not Compliant
Non-compliance doesn’t necessarily mean a direct EU fine lands on a US company’s desk, enforcement is handled at the member-state level and primarily targets products once they’re in the EU market. The more immediate business risk is commercial: distributors, resellers, and EU-based customers routinely require compliance documentation before they’ll carry a product at all, and non-compliant equipment can simply be refused entry or pulled from sale. For a company selling globally from a US base, converting manufacturing practices to meet RoHS is usually a smaller cost than losing access to EU-dependent sales channels.
Frequently Asked Questions
What's the difference between RoHS and REACH?
RoHS restricts ten specific substances in electrical and electronic equipment. REACH is a much broader EU regulation covering nearly all chemicals across every industry, with its own separate restricted-substance list. The two apply independently, so meeting RoHS doesn’t automatically satisfy REACH requirements.
Does RoHS apply to me if I only sell through distributors, not directly to EU customers?
Yes. RoHS compliance follows the product into the EU market regardless of how it gets there. If your equipment ends up in the hands of EU end users through a distributor or reseller, compliance still applies, and those partners will typically require documentation before they’ll carry non-compliant products.
What substances does RoHS restrict, and in what amounts?
RoHS restricts ten substances, including lead, cadmium, mercury, hexavalent chromium, and several brominated and phthalate compounds, to below 1,000 ppm each (100 ppm for cadmium). The original six substances were restricted starting in 2006; four phthalates were added under RoHS 3, with enforcement beginning in 2019.
Can BESTProto provide RoHS compliance documentation for my assemblies?
Yes. BESTProto’s assembly processes, including lead-free soldering, are built around RoHS-compliant practices, and we can provide compliance documentation for your assemblies on request.
How BESTProto Supports RoHS Compliance
BESTProto’s assembly processes are built around RoHS-compliant practices, including lead-free soldering capability for customers who need it (see our lead-free soldering capabilities for the alloys and processes we support). We can provide compliance documentation for your assemblies on request. For the full picture of our certifications and compliance posture, see our Compliance and Certifications page.
If you’re working toward RoHS compliance for a product headed to EU markets, contact us or request a quote to talk through what that means for your build.