Restriction of the use of certain hazardous substances (RoHS) originated in a European Directive, which restricted the use of six substances in electrical and electronic equipment. The scope of RoHS in the EU is expanding, and other jurisdictions (e.g., China) have adopted similar restrictions.

European Union


The EU adopted the Restriction of Hazardous Substances Directive (2002/95/EC), “RoHS” in 2003, and it took effect on July 1, 2006.  Directive 2011/65/EC (“RoHS 2” or  “RoHS Recast”), which replaced the original Directive, allows for updating the list of restricted chemicals and exemptions, and has provisions to harmonize RoHS with other EU legislation including REACH.


RoHS restricts the use of six substances in electrical and electronic equipment. Restricted substances have a maximum concentration value tolerated by weight in homogeneous materials:
  • Cadmium (0.01 %)
  • Hexavalent chromium (0.1 %)
  • Lead (0.1 %)
  • Polybrominated biphenyls (PBB) (0.1 %)
  • Polybrominated diphenyl ethers (PBDE) (0.1 %)
  • Mercury (0.1 %)

Additional substances may be restricted in the future.  Priority substances for potential addition are hexabromocyclododecane (HBCDD), bis (2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP).

The maximum permitted concentrations apply for each homogeneous material in the product, which means that the limits do not apply to the weight of the finished product, or even to a component, but to any material in the product that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing or cutting.

Compliance is the responsibility of the party placing the EEE on the market in the EU.  This includes manufacturers of EEE, with certain obligations on importers, distributors, and authorized representatives.  However, since restrictions apply at the homogeneous material level, data on substance concentrations need to be transferred through the supply chain, and thus material and component suppliers often need to certify RoHS compliance to their customers.

The CE mark is the permitted indication of RoHS compliance.  A product sold with the CE mark must meet RoHS requirements (as well as other requirements associated with the CE mark).

Electrical and Electronic Equiptment

The categories of electrical and electronic equipment (EEE) covered by the RoHS directive are:

  • Consumer equipment
  • Lighting equipment
  • Electrical and electronic tools
  • Toys, leisure and sports equipment
  • Medical devices
  • Automatic dispensers
  • IT and telecommunications equipment
  • Small household appliances
  • Large household appliances
  • Other EEE not covered by any of the categories above
  • Monitoring and control instruments including industrial monitoring and control instruments

The following are specifically exempt from the Directive:

  • Large-scale stationary industrial tools
  • Large-scale fixed installations
  • Most means of transport for persons or goods
  • Equipment designed to be sent into space
  • or does not fall within the scope of RoHS
  • Active implantable medical devices
  • Non-road mobile machinery made available exclusively for professional use
  • Equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis
  • Certain equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded 
  • Equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes
  • Photovoltaic panels intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications

In addition, there is a procedure for applying for exemptions for specific applications, and many of these have been granted.  The exempted applications are listed in Annex III and Annex IV of the current Directive.

Manufacturers of EEE

Manufacturers that place EEE on the market generally must:

  • ensure that it has been designed and manufactured in accordance with RoHS requirements set out in Article 4;
  • draw up technical documentation and a declaration of conformity, and affix the CE marking on the finished product;
  • keep the technical documentation and the declaration of conformity for 10 years after the EEE has been placed on the market;
  • keep a register of non-conforming EEE and product recalls, and keep distributors informed thereof;
  • ensure that their EEE bears a type, batch or serial number or other element allowing its identification, or, where the size or nature of the EEE does not allow it,  that the required information is provided on the packaging or in a document accompanying the EEE;
  • indicate their name, registered trade name or registered trade mark and the address at which they can be contacted on the EEE or, where that is not possible, on its packaging or in a document accompanying the EEE; and
  • for EEE placed on the market that is not in conformity, immediately take the necessary corrective measures to bring that EEE into conformity, to withdraw it or recall it, if appropriate, and immediately inform the applicable competent national authorities.

In the case of an imported product, the Directive lays out the responsibilities of the importer, which are similar to what would be required of the EU manufacturer (if the product were made in the EU).

The materials available and information provided at the Avery Dennison ADvantage: Complete Compliance site are for informational purposes only and not for the purpose of providing legal advice.



California has a “RoHS”-like law (CA RoHS).   CA RoHS applies to anyone who sells, or offers for sale, a covered electronic device in California.  This includes manufacturers, distributors, wholesalers, and retailers who sell covered electronic devices in California.

CA RoHS was modeled after the EU RoHS legislation, but there are important differences between the two.

  • While the EU RoHS Directive applies to a wide range of electrical and electronic equipment, CA RoHS restrictions are limited to covered electronic devices, which are specific video display devices that have been listed in DTSC’s regulations.
  • CA RoHS regulations restrict the use of lead, mercury, cadmium, and hexavalent chromium in certain electronic devices.
    • CA RoHS does not restrict the use of two brominated flame retardants that EU RoHS does restrict (polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs)).

Manufacturers of electronic devices covered by CA RoHS are required to report to the CA Department of Resources Recycling and Recovery on devices sold during the previous calendar year, by July 1 each year.

CA RoHS regulations apply only to covered electronic devices manufactured on and after the date that the devices first became subject to the California RoHS regulations.

Covered Electronic Devices

Under CA RoHS, a covered electronic device is a video display device with a screen greater than four inches, measured diagonally, which DTSC has identified in regulation as a device that is presumed to be hazardous waste when discarded.

  • video display device is an electronic device with an output surface that displays, or is capable of displaying, moving graphical images or a visual representation of image sequences or pictures, showing a number of quickly changing images on a screen in fast succession, to create the illusion of motion.  This definition includes, if applicable, any device that is an integral part of the display, in that it cannot easily remove it from the display.  A video display device may use, but is not limited to, a cathode ray tube (CRT), liquid crystal display (LCD), gas plasma, digital light processing or other image projection technology.

DTSC has identified and listed nine categories of covered electronic devices in its regulations. The list of devices includes:

  • Cathode ray tube containing devices (CRT devices)
  • Cathode ray tubes (CRTs)
  • Computer monitors containing CRTs
  • Laptop computers with liquid crystal display (LCD)
  • LCD containing desktop monitors
  • Televisions containing CRTs
  • Televisions containing LCD screens
  • Plasma televisions
  • Portable DVD players with LCD screens

There are exclusions for certain video display devices including:

  • A video display device that is a part of a motor vehicle
  • A video display device that is contained within or a part of a piece of industrial, commercial, or medical equipment, including monitoring or control equipment
  • A video display device that is contained within a clothes washer, clothes dryer, refrigerator, refrigerator and freezer, microwave oven, conventional oven or range, dishwasher, room air-conditioner, dehumidifier, or air purifier


The materials available and information provided at the Avery Dennison ADvantage: Complete Compliance site are for informational purposes only and not for the purpose of providing legal advice.



“China RoHS” is the law “Administration on the Control of Pollution Caused by Electronic Information Products,” which came into force in China on March 1, 2007.  Although it has come to be known as China RoHS, the requirements are notably different and more extensive than those of the EU RoHS.

China RoHS has two main sets of requirements for electronic information (EIP) products:

  • Substance restrictions and associated pre-market testing and compliance certification
  • Mandatory marking and/or information disclosure required for all EIP placed on the market on or after March 1, 2007

Electronic Information Products (EIP) include:

  • Radio and television products
  • Specialized electronic products
  • Electronic materials and accessories
  • Electronic communication products
  • Electronic radar products
  • Electronic application products
  • Computer products
  • Electronic components and parts
  • Home electronic products
  • Electronic instrument measuring products

The MII Electronic Information Products Classification and Explanations (“Catalogue”) provides a list of over 1800 specific EIP products, components, and materials that must comply with substance restrictions and labeling, information disclosure, and testing requirements.

The Catalogue specifies:

  • Categories of hazardous substances restricted for use
  • Categories of products
  • Timeline by which the designated products must comply with the hazardous substance restrictions and associated pre-market testing and compliance certification

China RoHS restricts the same chemicals (with same maximum concentration value) as the EU RoHS:

  • Lead (0.1 %)
  • Mercury (0.1 %)
  • Cadmium (0.01 %)
  • Hexavalent chromium (0.1 %)
  • Polybrominated biphenyls (PBB) (0.1 %)
  • Polybrominated diphenyl ethers (PBDE) (0.1 %)

The chemical restrictions are set out in the standard “Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products,“ SJ/T 11363-2006.

The scope of covered items in China is different than for EU RoHS, and China RoHS in general does not have exemptions.  Rather, it limits applicability by creating an extensive and significant catalogue of covered products.

China Labeling, Information Disclosure, and Testing Requirements

Electronic information products (EIPs) listed in the Catalogue must be marked with logos in accordance with the standard SJ/T11364-2006 (“Marking for Control of Pollution Caused by Electronic Information Products”).

If an EIP does not contain more than the maximum concentration value (MCV) of any restricted substances, it must be marked with a green “e”. If an EIP contains a restricted substance above the MCV of any restricted substances, then it must be marked with the product’s “environment friendly use period” (EFUP).  

  • The EFUP is the period during which the toxic substance contained in the EIP will not, under normal conditions of use, leak or mutate and result in pollution, injury, or damage.
  • The EFUP is provided inside the figure in the logo and is indicated in years (e.g. 50 = 50 years EFUP).
  • A table listing the hazardous substances and specified information must be provided.

Components that are intended to be used directly by an end customer need to be labeled.  Component suppliers do not need to provide the marking but do need to supply all necessary information to the purchaser.

EIPs listed in the Catalogue require pre-market testing and certification by a Chinese certified test lab.

  • The testing methods to be used by laboratories are described in the standard SJ/T11365-2006  (“Testing Methods for Regulated Substances in Electronic Information Products”).
  • The China Compulsory Certification (CCC) mark is required for EIPs in the catalogue.  CCC requirements incorporate China RoHS compliance testing.  The CCC is Administered by the Chinese government agency, Certification and Accreditation Administration (CNCA).
  • The process for applying for a CCC mark requires testing at accredited laboratories in China. 
  • The Packaging requirements referenced within China RoHS refer to an existing compulsory national standard, Packaging Recycling Marks, standard #GB 18455 on packaging recycling marks.  Packaging materials are required to be marked with the appropriate recycling mark and name of the packaging material.

The materials available and information provided at the Avery Dennison ADvantage: Complete Compliance site are for informational purposes only and not for the purpose of providing legal advice.

The Rest of the World


Scope of products covered is widening in some regions. EU and possibly others are adding to the list of substances covered. More countries are passing RoHS legislation similar to that in the EU.

Turkey RoHS legislation became effective June 2009.  Turkey’s requirements are aligned with EU RoHS.

The Eurasian Economic Commission (encompassing Russia, Kazakhstan, and Belarus) undertook a consultation on a draft RoHS in 2014.  The draft includes requirements that are very similar to EU RoHS but more narrowly define covered products.

In Japan, manufacturers and importers of specific types of electronic equipment are required to provide information on six substances (same as covered in EU RoHS).

  • Content markings are to indicate whether the content rate of the targeted substances is within or exceeds the standard value.
  • Japanese Industrial Standard JIS C 0950:2005 specifies the markings to be used to indicate the presence of hazardous chemical substances in electrical and electronic equipment.

South Korea
The South Korea Act on the Recycling of Electrical and Electronic Equipment and Vehicles contains substance restrictions and maximum concentration values (MCVs) are the same as under the EU RoHS.  There are also exemptions similar to those in the EU RoHS.  However the scope of covered products is narrower than under EU RoHS, and is limited to ten specified types of consumer products:

  • Air conditioners
  • Televisions
  • Refrigerators
  • Washing machines
  • Copiers
  • Printers
  • Fax machines
  • Personal computers
  • Audio equipment
  • Cell phones (including batteries and chargers)

India has RoHS provisions that came into force on May 1, 2014, but there is uncertainty about how the will be implemented and enforced.  Provisions are very similar to EU RoHS.