What Is EU RoHS?

EU RoHS is the Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment. It applies to a broad range of electrical and electronic equipment, including household appliances, IT equipment, consumer electronics, lighting equipment, tools, toys, medical devices, monitoring and control instruments and other EEE categories unless a specific exclusion applies.

RoHS is closely linked to CE marking because products in scope must demonstrate conformity before being placed on the EU market. This means companies need more than a supplier statement. They need a controlled compliance process, technical documentation, risk-based supplier evidence, product-level assessment and a valid EU Declaration of Conformity.

EU RoHS Restricted Substances

RoHS restricts ten substances or substance groups in homogeneous materials. A homogeneous material is a material that cannot be mechanically separated into different materials, such as a plastic casing, solder joint, coating, wire insulation, metal alloy or component material.

The current EU RoHS restricted substances are:

A key point for compliance teams is that RoHS limits are not calculated against the total product weight. They apply at homogeneous material level. This is why a product-level “RoHS compliant” statement is only reliable if the supporting evidence covers the relevant parts, materials and suppliers.

Latest EU RoHS Updates

1. Major 2025 Updates to Lead Exemptions Under Annex III

One of the most important recent changes is the update of several lead-related exemptions in Annex III of the RoHS Directive. The EU published three delegated directives in 2025 covering:

• Lead as an alloying element in steel, aluminium and copper
• Lead in high melting temperature solders
• Lead in glass or ceramic components

These updates are important because many electronic products, components and materials still rely on RoHS exemptions for technically necessary uses of lead. The latest amendments make the exemption structure more specific and introduce updated expiry dates, revised wording and narrower application conditions.

For compliance teams, this means it is no longer enough to record that a part uses “RoHS exemption 6”, “7(a)” or “7(c)”. Companies must verify the exact exemption sub-entry, check whether the application still fits the revised wording, confirm the expiry date and update the compliance status of affected SKUs.

2. Lead in Steel, Aluminium and Copper Alloys

The 2025 update for lead as an alloying element in steel, aluminium and copper affects commonly used exemption families under Annex III, including applications historically associated with exemptions 6(a), 6(b) and 6(c).

This matters for many product categories because metal alloys are widely used in connectors, mechanical parts, machined components, fasteners, terminals, housings and other electrical or electronic assemblies.

Key business impact:

• Companies should remap all products and components relying on lead in steel, aluminium or copper alloys.
• Existing supplier declarations may need to be updated because old exemption references may no longer be precise enough.
• Engineering and procurement teams should identify alternative materials where exemptions are narrowing or expiring.
• Compliance teams should update exemption registers and technical files.

3. Lead in High Melting Temperature Solders

Lead in high melting temperature solders has historically been one of the most widely used RoHS exemptions in electronics. The 2025 update revises the exemption for lead in high melting temperature solders and restructures the exemption into more specific applications.

This is significant because high-temperature lead solders can be used in demanding applications where thermal reliability, component performance or process limitations make substitution technically difficult.

Key business impact:

• Generic references to the high-temperature solder exemption should be reviewed.
• Suppliers should confirm the exact application and solder type.
• Companies should check whether the updated exemption wording still covers the use case.
• Products relying on this exemption should be flagged for expiry tracking and alternative planning.

4. Lead in Glass and Ceramic Components

The 2025 update also amends exemptions for lead in glass or ceramic components, including certain electrical and electronic components and dielectric ceramic applications. These materials appear in a wide range of components, such as capacitors, resistors, sensors, piezoelectric elements and other electronic parts.

Key business impact:

• Component-level evidence must be reviewed carefully.
• Exemption references should be updated to the revised Annex III entries.
• Supplier declarations should specify the relevant exemption sub-entry.
• Technical files should include justification showing why the exemption applies.

5. ECHA Will Play a Larger Role in RoHS Scientific and Technical Assessments

Another major development is Directive (EU) 2025/2456, which reassigns certain scientific and technical tasks under RoHS to the European Chemicals Agency (ECHA). This supports the EU’s “one substance, one assessment” approach, which aims to make chemical safety assessments more consistent, transparent and efficient.

In practice, ECHA will become more involved in:

• Assessing applications for granting, renewing or revoking RoHS exemptions
• Reviewing substances that may be added to the RoHS restricted substances list
• Supporting more harmonised and transparent technical assessments
• Aligning RoHS processes more closely with wider EU chemicals legislation such as REACH

For companies, this signals that RoHS substance and exemption management may become more structured, more data-driven and more aligned with ECHA-style evidence expectations. Compliance teams should expect stronger emphasis on technical justification, transparent dossiers, supplier evidence and traceable data.

6. No Broad RoHS Recast at This Stage, but Targeted Changes Continue

The European Commission’s RoHS review confirmed that RoHS remains relevant and continues to support the reduction of hazardous substances in EEE. However, instead of a broad recast at this stage, the EU has focused on targeted improvements, especially the reassignment of scientific and technical tasks to ECHA and the continued updating of exemptions.

This means companies should not wait for a “RoHS 3” reset before taking action. The compliance landscape is already changing through delegated directives, exemption updates, ECHA involvement and technical documentation expectations.

Why the Latest RoHS Updates Matter for Businesses

The latest RoHS changes increase the need for structured compliance management. Companies that sell EEE into the EU should review their current processes because many traditional approaches are no longer sufficient.

Common risks include:

• Outdated supplier declarations
• Missing homogeneous material evidence
• Incorrect exemption references
• Expired or soon-to-expire exemptions
• Technical files that do not align with EN IEC 63000
• Lack of traceability between products, parts, materials and suppliers
• Poor change control when suppliers, materials or components change
• Inability to respond quickly to customer or market surveillance requests

RoHS compliance is now a lifecycle activity. Products must remain compliant not only at launch, but also throughout production, supplier changes, product revisions, component substitutions and regulatory updates.

RoHS Compliance Checklist for 2026

Companies placing EEE on the EU market should consider the following steps:

1. Confirm Product Scope

Determine whether the product is electrical or electronic equipment under the RoHS Directive. Confirm the relevant EEE category and check whether any exclusion applies.

2. Build a Product-Part-Material Structure

RoHS compliance requires visibility beyond the finished product. A structured bill of materials should connect products to parts, components, subcomponents and materials.

3. Collect Supplier Evidence

Request up-to-date RoHS declarations, full material declarations, test reports, certificates or other supporting documents from suppliers. Evidence should be version-controlled and linked to specific parts or materials.

4. Assess Homogeneous Materials

Check whether each relevant homogeneous material complies with Annex II thresholds or whether a valid exemption applies.

5. Maintain an Exemption Register

Create and maintain a register of all RoHS exemptions used across products and components. The register should include exemption number, sub-entry, application, supplier evidence, affected SKUs, expiry date, renewal status and substitution plan.

6. Review the 2025 Lead Exemption Updates

Identify all products relying on lead in alloys, high-temperature solders, glass or ceramic components. Update exemption mapping and supplier declarations according to the revised Annex III entries.

7. Prepare EN IEC 63000-Aligned Technical Documentation

EN IEC 63000 is the key harmonised standard for technical documentation used to assess electrical and electronic products with respect to restricted substances. A strong technical file should include scope assessment, BOM, supplier evidence, risk assessment, test strategy where needed, exemption justification, compliance conclusion and approval records.

8. Update the EU Declaration of Conformity

The EU Declaration of Conformity should accurately reflect the applicable legislation, harmonised standards and product information. If a product changes, the DoC may need to be reviewed and updated.

9. Implement Change Control

Any supplier change, material substitution, component revision, manufacturing process change or exemption expiry should trigger a RoHS reassessment.

10. Be Ready for Market Surveillance

Authorities may request documentation. Companies should be able to retrieve technical files, declarations, supplier evidence and exemption justifications quickly and confidently.

How ComplyMarket Product Compliance Software Helps Meet EU RoHS Requirements

Managing RoHS manually with spreadsheets, email chains and static PDFs creates risk. It becomes difficult to know which products are compliant, which suppliers have missing evidence, which exemptions are expiring and which technical files are ready for audit or customer requests.

ComplyMarket Product Compliance Software helps companies manage RoHS compliance in a structured, scalable and traceable way.

1. Product-to-Part-to-Material Compliance Structure

ComplyMarket enables companies to manage product compliance data across products, parts, components and materials. This supports the homogeneous material logic required under RoHS and helps compliance teams understand where restricted substances may appear.

2. Supplier Evidence Collection and Version Control

The platform helps collect supplier declarations, supporting documents, test reports and material compliance data in one central system. Instead of relying on scattered emails, companies can manage supplier requests, reminders, document versions and evidence validity in a controlled workflow.

3. Automated RoHS Substance and Threshold Checks

ComplyMarket can support checks against RoHS Annex II restricted substances and thresholds. This helps identify missing data, high-risk materials, non-compliant parts and products that require further review.

4. RoHS Exemption Tracking

The latest EU updates make exemption management critical. ComplyMarket helps companies maintain an exemption register, map exemptions to affected products or SKUs, monitor expiry dates and identify where updated exemption wording may impact compliance status.

5. EN IEC 63000-Aligned Technical File Management

ComplyMarket supports structured technical documentation aligned with EN IEC 63000 expectations. This helps companies prepare evidence plans, organize supplier data, document risk assessments and maintain technical files that are easier to review, approve and retrieve.

6. EU Declaration of Conformity and Release Governance

The software supports controlled workflows for compliance approvals, product release decisions and Declaration of Conformity management. This ensures that products are not released without adequate evidence and that approvals remain traceable.

7. Change Control Across the Product Lifecycle

RoHS compliance must remain valid when products, suppliers, materials or components change. ComplyMarket helps trigger reassessments when changes occur, reducing the risk that a compliant product becomes non-compliant after launch.