RoHS
SERVICE INTRODUCTION
When mentioning import and export requirements for electrical and electronic products, one regulation that cannot be overlooked is RoHS. RoHS stands for Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment. It was initially proposed and implemented by the European Union. In 2003, the European Parliament and the Council issued Directive 2002/95/EC "Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment," which officially came into effect in July 2006, controlling six hazardous substances. In July 2011, the EU issued the updated RoHS Directive 2011/65/EU, which officially came into effect in 2013. This directive continued to primarily control the original six substances but added four candidate substances: HBCDD, DEHP, DBP, and BBP. In June 2016, the EU issued Amendment (EU) 2015/863 to Directive 2011/65/EU. This amendment explicitly required the addition of four phthalates to the controlled list: DEHP, DBP, BBP, and DIBP. It also expanded the scope of electrical and electronic products to include in vitro diagnostic medical devices and industrial monitoring and control instruments. The amendment officially came into effect on July 22, 2019 (for all products except in vitro diagnostic medical devices and industrial monitoring and control instruments) and on July 22, 2021 (for all electrical and electronic products on the list).
After the EU first implemented RoHS to control hazardous substances in electrical and electronic products, many other countries subsequently formulated and implemented similar regulatory controls. Below is a list of RoHS regulations in some major countries and regions:
| Country/Region/Organization | Regulation | Controlled Substances and Limits |
| European Union | Restriction on the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (2011/65/EU&Amendment(EU)2015/863) |
Lead (Pb): 0.1% Cadmium (Cd): 0.01% Mercury (Hg): 0.1% Hexavalent Chromium (Cr⁶+): 0.1% Polybrominated Biphenyls (PBBs): 0.1% Polybrominated Diphenyl Ethers (PBDEs): 0.1% Bis(2-ethylhexyl) phthalate (DEHP): 0.1% Benzyl butyl phthalate (BBP): 0.1% Dibutyl phthalate (DBP): 0.1% Diisobutyl phthalate (DIBP): 0.1% |
| United Kingdom | The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012(SI 2012/3032) |
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| South Korea | The Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles(Act No.17848) |
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| United Arab Emirates | Restriction on Hazardous Substances(UAE Cabinet Decision 10 of 2017) |
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| Vietnam | National technical regulation on the restriction of the use of certain hazardous substances in electrical and electronic equipment(QCVN 2022/BCT) |
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| China | GB 26572-2025 "Requirements for Limiting the Use of Hazardous Substances in Electrical and Electronic Products" | |
| Eurasian Economic Union | On the Limitation of the Use of Hazardous Substances in Electrical and Radio Electronics Products(EAEU TR 037/2016) |
Lead (Pb): 0.1% Cadmium (Cd): 0.01% Mercury (Hg): 0.1% Hexavalent Chromium (Cr⁶+): 0.1% Polybrominated Biphenyls (PBBs): 0.1% Polybrominated Diphenyl Ethers (PBDEs): 0.1% |
| Japan | The marking for presence of the specific chemical substances for electrical and electronic equipment (JIS C0950:2021) |
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| Thailand | Electrical and Electronic Equipment that May Contain Hazardous Substances:Restriction of the Use of Certain Hazardous Substance (TIS 2368-2564) |
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| Saudi Arabia | Technical Regulation for Restriction of Hazardous Substances in Electrical and Electronic Appliances and Equipment Guideline |
Applicable Types of Electrical and Electronic Products (taking EU RoHS as an example):
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools
7. Toys, leisure and sports equipment
8. Medical devices
9. Monitoring and control instruments
10. Automatic dispensers
11. Other electrical and electronic equipment
Do all materials in electrical and electronic products need to meet the regulatory limit requirements? The answer is no. Considering that some materials may inevitably contain restricted hazardous substances to achieve specific performance, or that alternative materials are costly and not economically viable, the RoHS regulation also includes an exemption list. Due to the extensive content of the exemption list, it is not listed in full here. Some of the most common exemptions include:
| Clause | Exemption Content |
| 6(a) | Lead as an alloying element in steel for machining purposes and in hot-dip galvanized steel, with lead content up to 0.35% |
| 6(b) | Lead as an alloying element in aluminium, with lead content up to 0.4% |
| 6(c) | Copper alloys containing up to 4% lead |
| 7(a) | Lead in high melting temperature type solders (i.e., lead-based alloys containing 85% or more lead) |
| 7(c)-I | Lead in glass or ceramic of electrical and electronic components (except dielectric ceramic in capacitors) (e.g., piezoelectric devices) or in glass or ceramic matrix compounds |
| 7(c)-II | Lead in dielectric ceramic in capacitors with a rated voltage of 125 V AC or 250 V DC or higher, except for applications covered by clauses 7(c)-I or 7(c)-IV |
| 7(c)-V | Electrical and electronic components containing lead in glass or glass matrix compounds fulfilling any of the following functions: 1) Protection and electrical insulation for glass beads of high-voltage diodes and wafer glass layers based on lead-zinc-borate or lead-silicon-borate glass bodies; 2) Sealing between ceramic, metal and/or glass parts; 3) For bonding purposes within a process parameter window of < 500 °C with a viscosity of 10¹³.³ dPas ("glass transition temperature"); 4) Used as resistive material (e.g., ink) with a sheet resistance range of 1 ohm/sq to 1 Mohm/sq, excluding trimming potentiometers; 5) For chemically modified glass surfaces of microchannel plates (MCP), channel electron multipliers (CEM) and resistive glass products (RGP). |
| 7(c)-VI | Lead in ceramics in electrical and electronic components fulfilling any of the following functions (excluding items covered by Annex III clauses 7(c)-II, 7(c)-III and 7(c)-IV and Annex IV clause 14): 1) For lead zirconate titanate (PZT) based piezoelectric ceramics; 2) For ceramics providing a positive temperature coefficient (PTC). |
Some of the above exemptions had previously expired, but because stakeholders submitted exemption renewal applications to the EU before expiration, the EU initiated a re-evaluation of whether these exemptions should expire. As there is no final evaluation result yet, these exemption clauses remain valid.
On August 22, 2025, the CCTV News Broadcast program aired a news report on a standard release conference, prominently introducing the release of the mandatory national standard "Requirements for Limiting the Use of Hazardous Substances in Electrical and Electronic Products" (GB 26572—2025) and the press conference held by the Ministry of Industry and Information Technology. The standard will officially come into effect on August 1, 2027. For products produced or imported before the implementation date, enterprises will be given a one-year period to deplete inventory, meaning inventory products can still be sold until August 1, 2028. The release of this mandatory standard is of great significance; all relevant enterprises should attach importance to the control of hazardous substances in their products and prepare their supply chain management in advance.
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