The RoHS Directive (Restriction of Hazardous Substances) has been regulating the presence of hazardous substances in electrical and electronic equipment placed on the European Union market for over two decades. Its latest version, commonly known as RoHS 3, came into force on July 22, 2019, under the Delegated Directive (EU) 2015/863. Importantly, this document expanded Annex II to Directive 2011/65/EU (RoHS 2) by adding four additional chemical substances.
To the elements and compounds already restricted, such as lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE), the following were added:
- di(2-ethylhexyl) phthalate (DEHP),
- butyl benzyl phthalate (BBP)
- dibutyl phthalate (DBP)
- diisobutyl phthalate (DIBP)
Why were phthalates included in the RoHS amendment?
Phthalates are organic chemical compounds commonly used as plasticizers. They are added to polyvinyl chloride (PVC) to increase its flexibility and durability. Due to their low cost and favorable physical properties, they were widely used in industry for many years.
They can be found, among others, in:
- foils, varnishes, paints, and solvents,
- vinyl wallpapers, floor coverings, and window blinds,
- sports articles and car interior components,
- toys, air fresheners, and food packaging films.
Their widespread presence in everyday products as well as in electrical and electronic devices was the main reason they were restricted under the RoHS 3 directive.
What exemptions are still in place?
Six years have passed since RoHS 3 came into force. All transitional periods, including those for medical devices and monitoring and control instruments, ended in July 2021. This means that today almost the entire market is subject to full compliance.
In 2025, exemptions apply only to:
- spare parts and cables used to repair or upgrade equipment placed on the market before July 22, 2019.
- exemptions listed in the annexes to the directive, which are periodically reviewed and may be extended or phased out depending on the availability of safe alternatives.
What tests confirm compliance?
Any manufacturer wishing to place a product on the EU market is required to prove that the product meets the requirements of the RoHS Directive. In practice, this means that appropriate testing must be carried out.
At the RCC Research and Development Center, we perform comprehensive analyses covering RoHS 2 + phthalates. Moreover, in our chemical laboratory we conduct:
- screening tests to determine the concentration of lead, mercury, cadmium, total chromium, total bromine, and phthalates DEHP, BBP, DBP, and DIBP,
- detailed analyses identifying and quantitatively determining hexavalent chromium, as well as PBB and PBDE compounds.
Each stage is documented in a report and delivered to the client. This way, the manufacturer decides whether we proceed with further analyses or stop at a given stage.
RCC as support for manufacturers in 2025
In 2025, RoHS 3 is a standard, and compliance with it is a fundamental condition for operating on the EU market. Non-compliance means not only the risk of sanctions but also the loss of customer and business partner trust.
RCC supports manufacturers, importers, and distributors in the conformity assessment process. Thanks to the expertise of our specialists and our modern laboratory, we help bring products to market that meet legal requirements and are safe for users.
If you would like to check your products for compliance with the current RoHS, we invite you to contact our Research and Development Center..