RoHS Testing for Hazardous Substances in Electronic Equipment - FAQ

RoHS currently restricts the use of ten hazardous substances in electrical and electronic equipment. These include:

• Lead (Pb)
• Cadmium (Cd)
• Mercury (Hg)
• Hexavalent Chromium (Cr VI)
• Polybrominated Biphenyls (PBB)
• Polybrominated Diphenyl Ethers (PBDE)
• Bis(2-ethylhexyl) phthalate (DEHP)
• Butyl benzyl phthalate (BBP)
• Dibutyl phthalate (DBP)
• Diisobutyl phthalate (DIBP)

These substances fall into three primary categories:

• Heavy metals
• Brominated flame retardants
• Phthalate plasticizers

RoHS limits the concentration of each restricted substance within individual materials used to manufacture a product.

RoHS 3 is the industry term commonly used to describe the expansion of the original RoHS directive to include four additional phthalates.

These substances—DEHP, BBP, DBP, and DIBP—were added to the list of restricted substances because of concerns about potential health risks associated with long-term exposure.

Although many people refer to this update as “RoHS 3,” it is actually an amendment to the RoHS 2 Directive rather than an entirely new regulation.

If your product contains electrical or electronic components and will be sold or distributed within the European Union, RoHS compliance is likely required.

Even companies that manufacture components rather than finished products may need RoHS testing, since those parts often become part of larger assemblies sold into European markets.

Some products are exempt from RoHS requirements, so it’s important to evaluate each product individually.

RoHS requirements apply to each homogeneous material within a product rather than the finished product as a whole.

Depending on your product, testing may include materials such as:

• Metals and solder
• Plating and coatings
• Plastics and polymers
• Wire insulation
• Cable jackets
• Printed circuit boards
• Electronic components
• Connectors
• Adhesives

Because each material is evaluated separately, products containing multiple materials often require multiple analyses.

RoHS establishes maximum allowable concentrations for each restricted substance within a homogeneous material. Current limits include:

• Cadmium: 0.01% (100 ppm)
• Lead: 0.1% (1,000 ppm)
• Mercury: 0.1% (1,000 ppm)
• Hexavalent Chromium: 0.1% (1,000 ppm)
• PBB: 0.1% (1,000 ppm)
• PBDE: 0.1% (1,000 ppm)
• DEHP: 0.1% (1,000 ppm)
• BBP: 0.1% (1,000 ppm)
• DBP: 0.1% (1,000 ppm)
• DIBP: 0.1% (1,000 ppm)

Exceeding these limits may prevent products from being legally placed on the EU market.

RoHS testing typically involves a combination of screening and laboratory analysis.

Many projects begin with X-ray fluorescence (XRF) screening, a fast, non-destructive technique used to detect regulated elements such as lead, cadmium, mercury, and bromine.

If additional confirmation is needed, laboratories perform more detailed analytical testing using specialized methods designed for specific substances, including heavy metals, phthalates, flame retardants, and hexavalent chromium.

An experienced laboratory can determine the appropriate testing strategy based on your product’s materials and compliance requirements.

Supplier documentation can often be a valuable starting point.

Material declarations, technical data sheets, and supplier certifications may help identify which substances are likely—or unlikely—to be present in your product. This information can reduce unnecessary testing by focusing only on materials that present potential compliance risks.

However, supplier documentation does not always replace laboratory testing. Manufacturers remain responsible for demonstrating compliance, and analytical testing is often recommended to verify supplier claims and support technical documentation.

To demonstrate RoHS compliance, manufacturers typically need to maintain several key documents, including:

• An EU Declaration of Conformity
• Technical documentation supporting compliance
• Supplier declarations and test reports
• The CE marking on the product

These records should generally be kept for 10 years after the product is placed on the European Union market.

Turnaround time depends on the number of materials being tested and the analytical methods required.

More complex products requiring multiple analytical methods may take additional time. Beginning the testing process early can help prevent delays when preparing products for the European market.

The cost of RoHS testing depends on several factors, including:

• The number of homogeneous materials
• Product complexity
• Testing methods required
• Whether screening or full laboratory testing is needed

Simple products typically cost less than complex assemblies with many components. RoHS testing is analytical laboratory testing, and a full test suite generally costs a few thousand dollars, making it a lower-cost compliance requirement compared with some programs that can cost tens of thousands of dollars or more.