RoHS

The ten restricted substances

RoHS restricts hazardous substances in electrical and electronic equipment placed on the EU market. The original directive covered six substances; RoHS 3 (Directive 2015/863/EU) added four phthalates, bringing the list to ten:

• Lead, mercury, cadmium, hexavalent chromium
• Polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE)
• The phthalates DEHP, BBP, DBP, and DIBP

Each has a maximum concentration value by weight in homogeneous materials — 0.01% for cadmium, 0.1% for the rest. “Homogeneous material” is the part that matters in practice: the limit applies to each individual material that cannot be mechanically separated, not to the average across the pack. A compliant pack overall can still fail on one non-compliant gasket or solder joint.

How compliance is actually evidenced

RoHS, like CE marking, is self-declared by the manufacturer or importer. There is no RoHS authority issuing certificates. What supports the declaration is a technical file, and for a battery pack that means material declarations and test data from the component suppliers — cells, BMS board, wiring, connectors, enclosure, potting compound, labels, adhesives.

This is why a supplier’s response to a RoHS request is informative. A factory that can produce substance declarations traced to each component supplier is running a real compliance process. A factory that produces a single generic certificate with no component traceability behind it is producing a piece of paper.

Third-party laboratory testing, typically by XRF screening followed by wet chemistry where a result is borderline, is commonly used to back the declaration. It is evidence supporting the declaration rather than a substitute for the supply chain data.

RoHS is not REACH, and neither is the Battery Regulation

Three EU regimes get conflated in sourcing conversations:

• RoHS — ten substances, in electrical equipment, at homogeneous material level
• REACH — a much broader chemicals regulation, including duties around Substances of Very High Concern in articles
• EU Battery Regulation 2023/1542 — battery-specific, covering carbon footprint, recycled content, due diligence, labelling, and end-of-life

They overlap in subject matter but impose different duties on different parties, and satisfying one does not satisfy another. Our EU importer checklist sets out which obligations land on the importer rather than on the factory.

Documentation on every order

RoHS documentation is a standard deliverable on every production order, covering all production lines. Where your own compliance process needs component-level substance declarations rather than a pack-level certificate, we can supply those on request — it is a reasonable thing to ask for, and it is the level at which the restriction actually operates.

RoHS also interacts with WEEE: both are EU product-stewardship regimes, but WEEE governs what happens at end of life and carries registration duties an importer must handle directly.