Powering the Future: Why Thermal Management Defines the Future of Electronics
Standard of Excellence: Engineering Is the New Sales—How Technical Collaboration Wins Business
SMT Perspectives & Prospects: Artificial Intelligence, Part 7—Data Module 2
What Electronics Manufacturers Need to Know About RoHS 3 Compliance
December 27, 2018 | David Weekes, JJS ManufacturingEstimated reading time: 3 minutes
On July 22, 2019, the latest incarnation of RoHS (the Restriction of Hazardous Substances) will come into full effect across the European Union.
So, what’s changed? And what exactly are the implications for UK electronics manufacturers?
In this article, we provide a recap of what RoHS is, why it matters, and the steps that OEMs will need to take to ensure compliance.
What is RoHS?
RoHS originated in the European Union in 2002 with the aim of restricting the use of specific hazardous substances found in the manufacture of electrical and electronic equipment (EEE) that have been identified as presenting a risk to human health and the environment.
The original directive 2002/95/EC known as RoHS laid down restrictions in relation to six key hazardous substances:
- Lead (Pb): found in printed circuit board (PCB) finishes, paints and pigments
- Mercury (Hg): used in lighting applications and automotive switches
- Cadmium (Cd): used in plastic pigmentation and photocells
- Hexavalent Chromium (CR VI): used to prevent corrosion of metal finishes
- Polybrominated biphenyls (PBBs): primarily used as flame retardants
- Polybrominated Diphenyl Ethers (PBDEs): primarily used as flame retardants
How has RoHS changed?
In 2011 came the publication of the directive 2011/65/EU, known as RoHS 2 or RoHS Recast, which took formal effect in July 2013. A significant addition to RoHS 2 was the inclusion of the CE-marking directive—the requirement for a certification mark that indicates that a product conforms with all health and safety and environmental protection standards within the European Economic Area.
The newest update of the directive 2015/863, known as RoHS 3, adds another four substances to the original list of six. All the new additions are forms of phthalates—the family of chemical compounds used to add flexibility, durability and transparency to plastics:
- Bis(2-ethylhexyl) phthalate (DEHP): a plastic polymer (plasticizer) previously used in cable and wire insulation, as a dielectric in large high-voltage capacitors, as a processing aid for rigid polymers and as a softener in a wide array of PVC medical devices.
- Butyl benzyl phthalate (BBP): occasionally used as a co-plasticizer in wire and cable; as an additive in flexible adhesives, coatings and inks; and in polyurethane adhesives, polyurethane rubbers and acrylic-based polymers.
- Dibutyl phthalate (DBP): used as a plasticizer in flexible varnishes, nitrocellulose paints and paper coatings; to "size" glass fiber and to add flexibility to rubbers and paints.
- Diisobutyl phthalate (DIBP): a plasticizer known to hold very similar properties to DPB but generally not known to be used in electronic products.
Who needs to comply?
If you're an electronics manufacturer who sells applicable electronic products or sub-assemblies to EU or countries—or if you're supplying to resellers or distributors who sell products on to RoHS countries—then RoHS 3 compliance applies to you.
For UK OEMs, this means ensuring that none of your products exceed the maximum prescribed levels of any of the 10 restricted substances on the RoHS list. You will also be required to keep records to demonstrate this compliance and to hold onto these records for a minimum of 10 years.
Required compliance record-keeping can also include providing evidence of CE marking, proof of compliance throughout the production process and along the entire supply chain, records of conformity assessments and the self-reporting of any instances of non-compliance.
In the event that a product is found (or is suspected) to be non-compliant, all parties will need to take steps to inform UK Safety and Standards, to notify the supply chain and to take appropriate remedial action, whether by fixing, quarantining, recalling or withdrawing the item.
Further guidance
For a deeper understanding of RoHS, including additional guidance for manufacturers, importers and distributors, the National Measurement & Regulation Office have produced a 39-page report which can be downloaded here.
This article originally appeared on the JJS Manufacturing blog, which can be found here.
Share on:
Testimonial
"Advertising in PCB007 Magazine has been a great way to showcase our bare board testers to the right audience. The I-Connect007 team makes the process smooth and professional. We’re proud to be featured in such a trusted publication."
Klaus Koziol - atgSuggested Items
Dan’s Biz Bookshelf: ‘iWar: Fortnite, Elon Musk, Spotify, WeChat, and Laying Siege to Apple’s Empire’
03/04/2026 | Dan Beaulieu -- Column: Dan's Biz Bookshelf"iWar: Fortnite, Elon Musk, Spotify, WeChat, and Laying Siege to Apple’s Empire" is not just a book about Apple, it’s a masterclass in leadership, ego, innovation, and the high cost of brilliance when vision collides with personality. Tim Higgins delivers a sharp, deeply reported account of Apple’s most turbulent years, showing how internal power struggles shaped the products that changed the world.
Technica USA and Electro Design AB Form Strategic Partnership
03/02/2026 | Technica USAOn March 2, 2026, Technica USA announced a strategic partnership with Electro Design AB. Under this agreement, Technica will serve as the Master Distributor in the United States and Canada for Electro Design's automation products for the SMT/PCBA market, marketed under the brand name “Technica, U.S.A. by Electro Design.”
The Performance-enhancing Benefits of Flexible Circuit Technology
02/05/2026 | Joe Fjelstad, Verdant ElectronicsFlexible circuits have been around much longer than most folks realize. My friend, Dr. Ken Gilleo, unquestionably a technology forensics genius, unearthed a British patent issued to Albert Hansen of Germany just after the turn of the last century (Figure 1), which we can easily recognize today as an ancestral flexible circuit. We owe his creativity a great deal of credit for laying the foundation for countless electronic products in use today that employ flex circuits.
Learning With Leo: The Disappearing Manufacturing Engineer
02/04/2026 | Leo Lambert -- Column: Learning With LeoManufacturing engineers are the firefighters of the manufacturing process, but as the industry changes the roles of the manufacturing engineer and manufacturing facilities export their manufacturing offshore, what happens to the function, viability, and knowledge of the manufacturing engineer? Where design engineering was known as a profession, manufacturing engineering was known as a job, not a career path. Although I was disappointed about that at the time, now I look back and wonder about the truth of that statement.
Learning with Leo: The Cost of Training on Skills and Knowledge Development
01/07/2026 | Leo Lambert -- Column: Learning With LeoThe ability to manufacture electronic products requires specific skills and knowledge, which have traditionally been developed through on-the-job experience and training. These experiences and training programs are expensive to implement, yet they are necessary to meet customer demands and remain competitive in the marketplace. Today, manufacturers, including government contractors, rely on industrial specifications in the design, fabrication, and assembly of electronic products.