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Regulation explainer

What is RoHS Directive 2011/65/EU — Restriction of Hazardous Substances in Electronics, and does it apply to your product?

small importers/resellers shipping to European Union. Drafted with AI assistance from the regulation dataset and approved by a person before publication; see the editorial policy.

Guide

If you're importing or reselling electronics into the EU, RoHS Directive 2011/65/EU is one of the first things you need to check. It restricts ten hazardous substances in electrical and electronic equipment, and the limits are specific:

  • **Lead (Pb):** 1,000 ppm
  • **Mercury (Hg):** 1,000 ppm
  • **Cadmium (Cd):** 100 ppm
  • **Hexavalent Chromium:** 1,000 ppm
  • **PBB:** 1,000 ppm
  • **PBDE:** 1,000 ppm
  • **DEHP, BBP, DBP, DIBP (phthalates):** 1,000 ppm each
  • These are measured by weight, per homogeneous material — meaning each individual component, coating, or part of your product needs to fall under these thresholds, not just the finished product as a whole. A cable jacket, a solder joint, and a plastic housing are each assessed separately.

    RoHS applies broadly: cables, chargers, LED lighting, toys with electronic components, kitchen gadgets, wearables, batteries built into devices, and most anything with a circuit board or plug. If your product has a battery, a motor, an LED, or connects to power, assume RoHS is in scope until proven otherwise.

    **What documentation you'll need:**

  • RoHS Declaration of Conformity
  • Material Composition Report (MCR)
  • XRF (X-ray fluorescence) test results
  • Supply chain RoHS certificates from your component suppliers
  • ICP-OES or ICP-MS test reports for the restricted metals
  • Many importers assume their supplier "already handles RoHS" — but without the actual test re

    Complyra checks product and supplier information against regulatory requirements to support procurement decisions. It does not issue certifications or guarantee legal compliance; final responsibility for compliance remains with the buyer and supplier.