EU RoHS Enviropass



The meaning of RoHS is Restriction of the use of certain Hazardous Substances.


You can choose three types of services as needed for your RoHS 3 Europe testing of CE marking certification under directives 2011/65/EU, 2015/863/EU:

  • Classic EU RoHS
  • Deluxe EU RoHS
  • Documentary Review


With Classic EU RoHS, you allow Expertise Enviropass to undertake the documentary assessment of your products. 


A Certificate of Conformity is issued for each product in compliance with the requirements of Europe RoHS.



Deluxe EU RoHS does not only provide you with fishes… but also teaches you how to fish! Indeed Deluxe EU RoHS includes:

  • Training in products auditing that will allow you to analyze more products yourself
  • Adapting technical documentation procedures and making you a master in monitoring your products compliance in regards to the Europe RoHS
  • Evaluating a product's assessment and issuing a Certificate of Conformity if applicable


You have built the technical documentation for a product yourself, but you want to make sure that the data quality is sufficient ? Let Enviropass:

  • Review your technical documentation
  • Advise you on potential gaps

  • Issue an applicable Certificate of Conformity

General RoHS Exemptions List
Eu RoHS list of exemptions with applicable expiration dates
RoHS exemptions AH December 7th 2019.pdf
Adobe Acrobat Document 464.7 KB
Medial Devices and Monitoring and Control Instruments RoHS Exemptions List
Eu RoHS list of exemptions
RoHS exemptions Medical Monitoring and C
Adobe Acrobat Document 218.8 KB

Categories of EEE covered by this Directive

1. Large household appliances.

2. Small household appliances.

3. IT and telecommunications equipment.

4. Consumer equipment.

5. Lighting equipment.

6. Electrical and electronic tools.

7. Toys, leisure and sports equipment.

8. Medical devices.

9. Monitoring and control instruments including industrial monitoring and control instruments.

10. Automatic dispensers.

11. Other EEE not covered by any of the categories above

RoHS Europe


  • RoHS imposes limitations for concentrations of lead (Pb), cadmium (Cd), mercury (Me), hexavalent chromium (Cr 6+), polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs) contained in electrical and electronic equipment.
  • From 22 July 2019 (or 2021 for products categories 8 and 9), 4 phthalates are also added to the restricted substances list: BBP, DBP, DEHP and DIBP under delegated Directive 2015/863, sometimes called RoHS 3.
EU RoHS electronics
  • The concentrations of the restricted substances are not regulated at the component level, but at the homogeneous materials level, which constitutes each component.
  • Therefore, one to dozens of homogeneous materials should be analyzed within the same component (i.e. various plastics, metals, ceramics, epoxy finishes, painting, welding etc.) one by one…
  • In order to confirm EU RoHS conformity of an assembly, you should not only consider each electronic component, but also the materials of every cable, label, hardware (such as screws...), solder, paste, casing, chassis, etc... in other words, wherever restricted substances may be found.
  • If it is out of the RoHS scope, then CE marking may still be mandatory, according to other requirements - related to electrical safety or EMC (electromagnetic compatibility) for example.
  • RoHS allows restricted substances to be exempted for certain categories of products and applications. However, several of these RoHS exemptions expire. Therefore, the expiration dates on exemptions must be monitored as they are regularly updated.
Product assessment
  • Statistically, manufacturers declare at least one RoHS exemption in 90% of their Printed Circuit Board Assemblies (PCBA) and Electrical and Electronics Equipment (EEE).
  • As per Directive 2011/65/EU, technical product documentation with procedures must now be prepared and provided upon request to surveillance authorities.
  • Asking a supplier if he is compliant to RoHS or finding a RoHS logo on a spec. sheet is not sufficient. Indeed, the manufacturer’s declarations of conformity the (DoC) must be collected, specifying whether exemptions are used and if so, what they are.
  • Complying with the European RoHS does not automatically imply that it will conform to the China RoHS. However, the information already gathered will be valuable and will simplify the compliance process with China RoHS.

BOM assessment of electronic product




You must ensure compliance with restricted substances thresholds, and monitor any reported exemptions.


In the vast majority of cases for PCBA and complex products, the documentation review from suppliers and subcontractors is the best option because unlike chemical analysis or other analytical tests (i.e. XRF testing), it enables:

  • Better money value for the assessment of all the homogeneous materials which constitute a product
  • To check and reuse the tests already carried out by the suppliers instead of redoing them
  • To find out which exemptions numbers have already been claimed
  • To monitor products compliance over the changing requirements (i.e. changes in exemptions) or new designs (i.e. replacement of suppliers, of parts etc.). Only the documents of affected parts will be reviewed
  • To build robust technical documentation.

Since its introduction, the standard EN 50581 / IEC 63000 - Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances - recommends the documentary approach with suppliers, which is recognized by both industry and enforcement authorities.


In the absence of sufficient documentation for a component, a risk analysis is conducted and recommendations are given (either chemical analysis or component replacement). Chemical analysis is therefore taken as a last resort, only after a careful documentary review, and focuses on uncertain homogeneous materials only.



With EU RoHS, it is mandatory to build technical file showing the method for verifying a product’s compliance.


The technical documentation must contain specific information documented in the procedure.

Technical Documentation - Table of Contents
Table des matières de la documentation technique
Technical Documentation - Table of Conte
Adobe Acrobat Document 353.1 KB