RoHS: measuring per homogeneous material

RoHS By Francois Frietman 8 minuten lezen
Short answer

The RoHS Directive restricts ten substances in electrical and electronic equipment. The limit values apply per homogeneous material, not to the product as a whole. Consequently, a single solder joint or a cable jacket can fail even if the product average is well within the limits.

This distinction is the reason why many technical files are still found to be insufficient during inspections.

The ten substances and their limit values

Annex II of Directive 2011/65/EU lists ten substances with a maximum tolerated concentration in homogeneous materials, expressed in weight percentage. Nine of these have a limit value of 0.1% by weight. Only cadmium is ten times lower, at 0.01%.

SubstanceLimit value
Lead0,1 %
Mercury0,1 %
Cadmium0,01 %
Hexavalent chromium0,1 %
Polybrominated biphenyls (PBB)0,1 %
Polybrominated diphenyl ethers (PBDE)0,1 %
Bis(2-ethylhexyl) phthalate (DEHP)0,1 %
Butyl benzyl phthalate (BBP)0,1 %
Dibutyl phthalate (DBP)0,1 %
Diisobutyl phthalate (DIBP)0,1 %
The restricted substances from Annex II and their maximum concentrations

The last four are phthalates, plasticizers used in plastics. They were added later, with a specific implementation date for medical devices and monitoring and control instruments. They have been applicable to other categories for a longer period.

What constitutes a homogeneous material

The directive defines a homogeneous material as a single material of uniform composition. Material that cannot be separated into different materials by mechanical actions also counts. Unscrewing, cutting, crushing, grinding, and abrasive processes are examples of mechanical actions.

In practical terms, this means your product consists of dozens to hundreds of homogeneous materials. The coating on a screw is one. The solder on a PCB is one. The insulation of a wire is one. The core of that same wire is another.

The limit value applies to each such material. Not per component, not per PCB, and certainly not per product.

Why an average is meaningless

A product weighing 800 grams containing 0.4 grams of lead is at 0.05% and appears to be well within limits. However, if that lead is contained in a solder joint of 0.5 grams, then that joint is 80% lead and the product fails. The question is therefore not how much is in it, but where it is located.

What this means for your technical file

You cannot demonstrate RoHS compliance with a single measurement of the complete product. You need supporting documentation per material. Or at least per component, backed by a supplier declaration. It is a chain of evidence rather than a single report covering everything.

In practice, you build this using a Bill of Materials (BOM). For each component, you record which materials it contains and what supporting evidence you have: a supplier declaration, a test report, or your own measurement. If supporting evidence is missing for a component, that constitutes a gap in your technical file.

Furthermore, this approach scales. If you use the same connector in ten products, you only need to arrange that supporting documentation once.

Which products it applies to

The directive applies to electrical and electronic equipment in eleven categories, ranging from household appliances and IT equipment to lighting, tools, toys, medical devices, monitoring and control instruments, and automatic dispensers. The eleventh category is a catch-all category for everything that does not fit into the first ten.

This catch-all category is important. It means you cannot conclude that RoHS does not apply simply because your product does not fit into one of the well-known categories. If it runs on electricity, assume it falls under the scope unless an exemption applies.

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    How to demonstrate compliance

    There are three levels of evidence, which are usually combined: a supplier declaration with a substance list, a screening with a handheld meter, and a laboratory analysis per material. Only the latter is a true measurement; the first two are indications.

    • Supplier declaration. Fast and inexpensive, but only as reliable as the supplier. Request the underlying reports.
    • Screening with a handheld meter. Quickly indicates where heavy metals are located, but measures at the surface and does not detect phthalates.
    • Laboratory analysis. Per homogeneous material, involving digestion and analysis. This is the evidence that holds up.

    The sensible route is a combination. Screening to identify high-risk areas, supplier declarations for the majority, and laboratory analysis for materials where the risk lies or where supporting evidence is missing.

    The difference with REACH

    RoHS and REACH are often confused. RoHS restricts ten specific substances in electrical equipment, per homogeneous material. REACH operates more broadly across all products, with a growing list of Substances of Very High Concern and an information obligation above 0.1% per article.

    They are not mutually exclusive. An electrical product falls under both. Therefore, your RoHS documentation says nothing about your REACH position. The reverse is also true.

    What you need to arrange

    Start with a Bill of Materials (BOM) listing the materials per component. Then determine for each component what supporting evidence you have and where it is missing. Have tests performed on the highest-risk areas: solder, coatings, cable insulation, plastics with plasticizers, and colored parts.

    1. Create a Bill of Materials (BOM) listing the materials contained in each component.
    2. Request a declaration from each supplier, including the underlying reports.
    3. Screen the product to see where heavy metals are located and where you need to look deeper.
    4. Have the high-risk areas analyzed per homogeneous material in a laboratory.
    5. Document the chain of evidence in your technical file, so that an inspector can trace from component to proof.

    From Bill of Materials to a conclusive technical file

    We build the chain: Bill of Materials, supplier declarations, screening, and analysis where necessary. You receive a technical file in which every material has a source. Fixed price in advance.

    View our services
    Sources
    • Directive 2011/65/EU, consolidated text with Annex II and the definition of homogeneous material , text on EUR-Lex
    • Delegated Directive (EU) 2015/863, which added the four phthalates to Annex II , text on EUR-Lex
    Legislation verified on August 16, 2026
    Francois Frietman
    Founder of Declaer

    Legal professional with a background in e-commerce. Writes about the regulations he applies daily in cases for brands and manufacturers. More about Francois

    Frequently Asked Questions

    Does the limit value apply to the entire product?
    No. The limit values apply per homogeneous material, not to the product as a whole. A single solder joint or cable jacket can fail while the average for the product remains well below the limit. The question is where the substance is located, not the total amount contained within the product.
    What exactly is a homogeneous material?
    A single material of uniform composition. It also includes material that cannot be mechanically disjointed into different materials. Unscrewing, cutting, crushing, grinding, and abrasive processes are considered mechanical actions. A coating, a solder joint, and wire insulation are each considered a separate material.
    Is a declaration from my supplier sufficient?
    As a starting point, yes; as conclusive evidence, usually not. Request the underlying reports and check whether they have been prepared per homogeneous material. A declaration without supporting documentation does not shift the risk to the supplier, as you are the one placing the product on the market.
    Is a handheld meter sufficient?
    No. A handheld meter is useful for quickly identifying the location of heavy metals, but it measures at the surface and does not detect the four phthalates. Use it to identify high-risk areas and then have those areas analyzed in a laboratory per material.
    Which products fall under RoHS?
    Electrical and electronic equipment in eleven categories, including household appliances, IT equipment, lighting, tools, toys, medical devices, and monitoring and control instruments. The eleventh category is a catch-all category, so falling outside the first ten does not mean falling outside the scope of the directive.
    Is RoHS the same as REACH?
    No. RoHS restricts ten specific substances in electrical equipment, measured per homogeneous material. REACH operates more broadly across all products, with a growing list of Substances of Very High Concern (SVHC) and an information obligation above 0.1% per article. An electrical product falls under both.