RoHS 4 is a planned extension of the EU RoHS Directive. It adds two new substances to the list of restrictions: MCCP and TBBPA. Unlike RoHS 3, which has included ten substances since 2019 (four of which are phthalates), RoHS 4 increases this number to twelve.
The purpose of these changes is to further protect human health and the environment by limiting the use of chemical compounds that may be toxic, bioaccumulative, or difficult to manage during recycling.
RoHS 3 – Expansion of the list with phthalates
The RoHS 3 Directive has been in effect since 2019. It introduced four new chemical substances to the list regulated by law: the phthalates DEHP, BBP, DBP, and DIBP. As a result, the catalog increased from six to ten substances.
In addition to elements such as lead, cadmium, mercury, and hexavalent chromium, as well as brominated compounds PBB and PBDE, manufacturers also had to control plasticizers. Phthalates are commonly used in PVC, toys, and everyday consumer products.
RoHS 4 – new substances under review
The next stage in regulatory development is RoHS 4, which covers two additional substances: MCCP and TBBPA. Their restriction was recommended by the Öko-Institut after analyzing seven chemical compounds in 2021.
- MCCP (Medium Chain Chlorinated Paraffins) chlorinated paraffins with medium-length carbon chains. They are primarily used as plasticizers in PVC and as flame retardants. The main concerns include aquatic toxicity, bioaccumulation, and exposure risks for recycling workers.
- TBBPA (Tetrabromobisphenol A) a brominated organic compound found in printed circuit boards and as a flame retardant additive in ABS plastics. In epoxy resins, it forms stable bonds with the polymer, but when used as an additive, it can be released into the environment.
For both substances, a limit of 0.1% in homogeneous material has been proposed.
Difference between RoHS 3 and RoHS 4
- RoHS 3 included 10 substances, adding four phthalates to the previous list.
- RoHS 4 expands the regulations with two additional substances: MCCP and TBBPA.
In total, this brings the list to 12 substances whose presence in products must be monitored. The difference lies not in how the directive works but in the further expansion of the list of restricted or limited materials.
What does this mean for manufacturers?
The new regulations require even more precise control of materials and components. A manufacturer cannot rely solely on supplier declarations — they must also have test results confirming product compliance.
In practice, this means the need to:
- Conduct screening and detailed testing of samples,
- Update technical documentation,
- Prepare accurate declarations of conformity,
- Verify the supply chain, especially for cables, PVC, PCBs, and ABS plastics.
How does RCC support this process?
At the RCC Research and Development Center, we conduct the full range of tests required by the RoHS Directive. We offer XRF screening analyses and detailed determinations of substances such as hexavalent chromium, PBB, and PBDE.
With the inclusion of MCCP and TBBPA on the restricted list, our laboratory provides manufacturers with comprehensive support — from testing and result interpretation to documentation preparation.
This ensures that our clients’ products comply with EU law while remaining safe for users and the environment.