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The European Union’s Restriction of Hazardous Substances (RoHS) Directive is one of the most critical environmental regulations affecting the electronics industry. Since 2006, it has helped reduce the use of toxic substances in electrical and electronic equipment (EEE), driving sustainability, product safety, and supply chain transparency.
But RoHS isn’t frozen in time. It evolves, and 2025 is a turning point. With exemptions expiring, new labeling mandates, and the early movements toward what many are calling RoHS 4, compliance is no longer just a checkbox—it’s a moving target.
RoHS Directive Evolution: RoHS 1 → RoHS 2 → RoHS 3
- RoHS 1: The Starting Point
Directive 2002/95/EC set the original foundation, restricting six substances:
- Lead (Pb) ≤ 0.1%
- Mercury (Hg) ≤ 0.1%
- Cadmium (Cd) ≤ 0.01%
- Hexavalent Chromium (Cr⁶⁺) ≤ 0.1%
- PBB and PBDE flame retardants ≤ 0.1%
These thresholds apply per homogeneous material, meaning each uniform substance in a component.
- RoHS 2: Modernizing the Framework
Directive 2011/65/EU, known as RoHS 2, introduced:
- Mandatory CE marking and a Declaration of Conformity (DoC)
- Expansion to 11 product categories
- Time-bound exemptions with structured renewals
- Technical file requirements with a 10-year retention period
- RoHS 3: Phthalates and Emerging Risks
Directive 2015/863 added four phthalates in 2019:
- DEHP, BBP, DBP, DIBP ≤ 0.1%
These plasticizers are common in cables, plugs, and molded parts, are now heavily scrutinized under compliance programs.
What’s New in 2025? Key RoHS Updates You Can’t Ignore
Cadmium in Quantum Dots – Exemption 39(a) Expires
Directive (EU) 2024/1416 phases out cadmium in quantum dots:
- 39(a) exemption ends November 21, 2025
- Replaced by 39(b)—valid only if cadmium is deposited directly on LED chips (expires Dec 31, 2027)
If you use quantum dots in displays or sensors, check whether your configuration still qualifies.
Lead & Cadmium in Recycled PVC – New Labeling Requirement
Directive (EU) 2024/232 allows continued use of recycled PVC containing lead/cadmium, but with stricter rules:
- Exemption valid until May 28, 2028
- From May 28, 2026, products with lead ≥0.1% must be visibly labeled
Applies primarily to EEE used in window and door profiles, such as smart home automation components.
RoHS Annex III Exemptions Expiring 31 December 2026
Critical exemptions (Annex III) are on the clock:
Note: These exemptions are not part of the 2025 Pack 28 consultation but are scheduled to expire unless renewed. Renewal requests for some (e.g., 6(a)–(c), 7(c)-I/II/V/VI) have been under evaluation in Pack 22–26
RoHS Technical and Supply Chain Requirements
1. CE Marking and DoC
CE marking under RoHS confirms that the product meets all restrictions. You must maintain:
- A signed Declaration of Conformity
- Supporting technical documentation
- Testing records or validated supplier declarations
2. 10-Year Documentation Retention
Manufacturers must retain the full technical file for 10 years after placing the product on the market.
3. Supply Chain Risk Management
Compliance extends beyond your own production—suppliers matter.
- Gather IPC-1752A or equivalent compliance declarations
- Audit critical suppliers
- Track exemption dependencies across your bill of materials (BOM)
Managing RoHS Exemptions: Time is Running Out
Exemptions are no longer forever. They are:
- Application-specific (e.g., ceramic capacitors in MRI machines)
- Time-bound and subject to renewal or removal
- Increasingly tied to sustainability evaluations
Tip: Use tools like Acquis to monitor exemption expiration, launch data requests, and maintain traceability.
What Products Are Covered?
RoHS applies to 11 EEE categories, including:
- Consumer electronics
- IT and telecom equipment
- Lighting and tools
- Medical devices and monitoring instruments
- Toys and leisure gear
Excluded: Military equipment, large-scale fixed installations, space systems, and active implants.
Enforcement: The Risks of Non-Compliance
Under the Market Surveillance Regulation (EU) 2019/1020, regulators can:
- Conduct unannounced audits
- Ban non-compliant products from the EU market
- Order product recalls
- Share enforcement actions via the Union Product Compliance Network (UPCN)
What’s Next? Subtle Shifts Toward RoHS 4
While not yet law, the European Commission is reviewing the RoHS Directive as part of the Chemicals Strategy for Sustainability. Key themes under discussion:
- Transfer of RoHS oversight to ECHA
- Integration with REACH, SCIP, and Digital Product Passport (DPP)
- Possible addition of PFAS or other hazardous substances
If you're waiting for an official "RoHS 4," you're missing the point the groundwork is being laid now. Smart manufacturers are proactively redesigning for future-proof compliance.
Leveraging Technology for Efficient RoHS Compliance
Effective RoHS compliance hinges on robust data management. Advanced solutions, such as Acquis platform, offer:
Automated supplier engagement for collecting compliance data. Real-time tracking of regulations and exemptions. Centralized dashboards for actionable insights. Scalable tools to manage complex supply chains.
Final Thoughts: Compliance Is a Moving Target
The RoHS Directive isn’t standing still. With exemptions sunsetting, new labeling requirements, and the future shape of RoHS 4 beginning to emerge, manufacturers must take a proactive, tech-enabled approach to compliance.
Don’t let exemptions slip through the cracks. Don’t wait for RoHS 4 to catch you off guard.
Stay ahead. Stay compliant. Stay competitive.
Talk to Acquis today about automated RoHS exemption tracking, supplier declaration workflows, and DPP-ready data frameworks.
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