UK RoHS Regulation : A Guide for Manufacturers, Importers, and Distributors

Let’s be honest: post-Brexit compliance isn’t just messy — it’s risky. If you’re placing electronic products in the UK market and think CE marking alone keeps you safe, think again.

UK RoHS — officially the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 — is its own regime now. It mirrors the EU RoHS Directive in substance, but the rules of the game have changed.

Here’s what you need to know to stay compliant, avoid fines, and keep your supply chain flowing smoothly.

What Is the UK RoHS Regulation?

The UK RoHS Regulation governs the restriction of ten hazardous substances in electrical and electronic equipment (EEE). While derived from the EU’s framework, it’s now enforced separately by the Office for Product Safety and Standards (OPSS) in Great Britain (England, Scotland, and Wales).

Products sold in Northern Ireland still follow EU RoHS and require CE marking. GB follows UK RoHS and requires UKCA — unless you're using the extended CE fallback.

Scope: Who and What Falls Under UK RoHS?

Applicable to:

• All finished EEE placed on the GB market

Not applicable to:

• Components not sold individually to the market
• Military and space equipment
• Large-scale fixed installations and stationary industrial tools

You must:

• Maintain a technical file (including risk assessment and supplier docs)
• Issue a Declaration of Conformity (DoC)
• Apply appropriate marking (UKCA or CE)

UK RoHS Restricted Substances and Limits (by weight in homogeneous material)

| Substance | Limit | | -------------------------- | ----- | | Cadmium (Cd) | 0.01% | | Lead (Pb) | 0.1% | | Mercury (Hg) | 0.1% | | Hexavalent Chromium (Cr⁶⁺) | 0.1% | | PBB | 0.1% | | PBDE | 0.1% | | DEHP | 0.1% | | BBP | 0.1% | | DBP | 0.1% | | DIBP | 0.1% |

If you’re over these thresholds in any homogeneous material, your product is non-compliant. No exceptions.

UKCA and CE Marking — What's the Deal?

GB Market: Use the UKCA mark NI Market: Use the CE mark (EU RoHS still applies)

As of August 2023, CE marking will continue to be recognized in GB for most product types beyond 2024 — but that’s not a permanent excuse to ignore UKCA prep.

UK RoHS Technical Documentation: Your First Line of Defense

To prove compliance, your technical file must include:

• Product design and manufacturing details
• Material declarations and test reports
• Risk assessments
• Supplier certifications
• DoC with product and issuer details

Pro tip: Maintain this documentation for 10 years post-placement.

Roles and Responsibilities Under UK RoHS

Manufacturers must:

• Ensure compliance and affix proper markings
• Create and retain technical docs and DoC

Importers must:

• Verify manufacturer compliance before import
• Maintain access to DoC and documentation

Distributors must:

• Check for proper labeling and documentation
• Refrain from placing non-compliant products on the market
• Assume full manufacturer responsibilities if modifying products

UK RoHS Enforcement and Penalties

If you're found non-compliant:

• OPSS can order withdrawals, recalls, and corrective actions
• Fines up to £20,000
• In severe cases, criminal prosecution (yes, really)

Don’t wait until an audit to get compliant — get ahead of it.

Conclusion: UK RoHS Isn’t Optional — It’s Strategic

If you want to keep selling in the UK, compliance isn’t just a box to check. It’s a core part of your go-to-market strategy.

UK RoHS = market access + brand trust + futureproofing.

Let Acquis Simplify Your UK RoHS Compliance

Tired of chasing certificates or emailing suppliers endlessly? Acquis helps you:

• Centralize RoHS data across suppliers
• Auto-generate UKCA-ready DoCs
• Track risk by BOM or component
• Prepare for OPSS audits with confidence

Book a demo today. Let’s turn compliance from chaos into competitive edge.