Adoption of RoHS Requirements in Key Global Markets

The impact of chemicals has always been a key concern throughout the product life cycle. For electrical and electronic equipment (EEE) manufacturers, the restriction of hazardous chemicals plays a crucial role in the policy framework of product compliance and market access. Aiming to protect human health and the environment, legislators and authorities have put forward different measures to restrict the concentration of hazardous substances present in EEE around the world.

Restriction of Hazardous Substances (RoHS) is a comprehensive piece of legislation specifically applicable to EEE, which usually requires the restriction of certain categories of hazardous substances concentration in EEE and/or the labeling of them. Regulations in some markets cover both requirements on substance concentration limit and labeling as obligations, while others might only take the first step, mandating the marking of the presence of restricted substances in products, but set no requirements on concentration limits. The approaches to demonstrating compliance are different. Most countries or regions adopt self-declaration from manufacturers, and some may also require certification.

This article aims to provide a comparative analysis of global RoHS requirements, as well as introduce recent regulatory updates of RoHS in some countries, both in progress and finalized. Since the EU RoHS Directive has, to some extent, served as a reference for relevant laws and regulations around the world¹, introducing the EU RoHS requirements should be a starting point to understand the RoHS regulations worldwide. Finally, this insight page serves as guidance to support EEE manufacturers in better understanding the policy focus of RoHS in different markets and fulfilling the compliance obligations.

1.   Scope of regulated products under RoHS requirements

Most countries or regions have defined a clear scope for regulated products under RoHS requirements, either by specifying macro product categories covering all types of EEE (open scope), or by listing specific product categories (with HS codes). The representative case of the former one is the EU. EU RoHS covers a wide range of product categories from large household appliances, IT and telecommunications equipment to medical devices and monitoring and control instruments², sharing the same list with Directive on Waste Electric and Electronic Equipment (WEEE)³. There is an additional category, “other EEE not covered by any of the categories above,” to catch all. Similar product scope can be found in China, United Arab Emirates (UAE) and those countries localizing EU RoHS Directive such as Turkey or Ukraine. For China, while almost all EEE are regulated in scope and mandatory for marking requirements, there is another smaller catalogue of 12 specific products published, which should fulfill the substance restriction requirements⁴. According to the most up-to-date draft announcement, the mandatory catalogue is expected to be expanded from 12 to 33 products⁵. For the other case, Japan, India, Vietnam, and Singapore are countries which have limited product scope, by checking the category names, descriptions or Harmonized System (HS) codes, manufacturers can evaluate the applicability of their products.

In general, the product scope tends to be continuously expanded.

In April 2025, the Ministry of Environment of South Korea announced the amendment of the Enforcement Decree of Act on the Resource Circulation of Electric and Electronic Products and Automobiles: starting Jan. 1, 2026, the list of EEE subject to RoHS requirements will be expanded from the existing 50 types of medium and large home appliances to almost all electrical and electronic products⁶. In July 2025, the Saudi Standards, Metrology and Quality Organization (SASO) published the draft Technical Regulation on the Restriction of Hazardous Substances in Electrical and Electronic Equipment, aiming to expand the current limited product categories to open scope⁷.

As exclusions, military/security equipment, large-scale stationary industrial tools and large-scale fixed installations, means of transport and any part or component specifically designed as part of the excluded products, etc., are generally not covered by the RoHS regulations. 

2. Regulated substances

In order to reduce the administrative burden and achieve coherence with newer EU policies and legislation, such as the Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)⁸, EU RoHS experienced a transition to extend the regulated substances from six categories to ten in 2011. In alignment with EU requirements, other key markets gradually adopted the complete ten categories of restricted substances. In 2024, China published an amendment to the China RoHS standard GB/T 26572-2011 Requirements of Concentration Limits for Certain Restricted Substances in Electrical and Electronic Products, adding four phthalates (DEHP, BBP, DBP, DIBP) to the restricted substances of electrical and electronic products. Later on, this voluntary industrial standard became a mandatory national standard, merging with SJ/T 11364-2024, Labeling requirements for restricted use of hazardous substances in electrical and electronic products. The mandatory standard GB 26572-2025 will be effective from Aug. 1, 2027⁹.

Markets such as Japan, India, Vietnam, Singapore and Saudi Arabia still have six restricted substances for the moment, but at least for Saudi Arabia, it can be foreseen that some actions are in progress to expand the categories of restricted substances to align with international requirements.

The United States of America doesn’t have regulations on restricted substances on the federal level, but state-level actions are in place. For example, California approved the requirements specifically for Cathode Ray Tube (CRT) and Liquid Crystal Display (LCD) containing devices (monitors, televisions, laptops, etc.). The focus substances are limited to four main categories.

There are also some typical exempted applications of restricted substances specified in the regulation, for example, the use of mercury in certain lighting equipment, the the use of lead for some medical devices and monitoring and control instruments.

3. Compliance documents

Most regulations require manufacturers’ self-declaration of compliance with substance restrictions. For EU RoHS, technical documentation for conformity assessment is needed, and shall be provided only upon request of local authorities. In some countries, suppliers should register in the specific official platform to provide and publish the self-declaration of conformity; examples are China, South Korea and India. To prove compliance with substance restrictions, voluntary certification of RoHS is also an option in China and Uzbekistan, in addition to self-declaration.

Some countries don’t have local RoHS regulations but directly require that products placed on their market shall comply with EU RoHS through certain trade mechanisms. Oman published the compliance requirement of telecommunications equipment and medical devices with EU RoHS through WTO notification in 2021¹⁵. Israel announced the “European Regulations Track,” through which manufacturers can import, manufacture, or market products that are subject to the official standard but comply with the requirements of the associated European regulations, including EU RoHS¹⁶.

4. Conformity marking

RoHS declaration usually shares the same mark from existing product compliance scheme of safety, e.g., CE marking of the EU, ECAS or EQM mark of the UAE, and the commodity mark of Taiwan. In other countries adopting RoHS and WEEE requirements in the same regulation, one consistent marking is required, e.g., the use of a cross-out wheeled bin symbol in Serbia.

China and Japan identified differentiated RoHS marking: green marking to show compliance with substance restriction, and orange marking to highlight the presence of restricted substances above the concentration limit requirements. This might lead one to think that RoHS compliance in Japan and China is not mandatory. This is not entirely true. First of all, labeling of restricted substances is a must, which may encourage consumers to select products with environmental benefits and, in turn, motivate manufacturers to comply with the substance concentration limit. In addition, as a further step, if the product is covered by the Catalogue of Compliance for the Restriction of Hazardous Substances in Electrical and Electronic Products in China, it is mandatory to comply with the substance restriction requirements and thus shall be labelled with additional green product compliance marking (SDoC or voluntary certification).

5. Summary

In total, 31 countries in the European Union, the EEA and EFTA have transposed the requirements of the EU RoHS Directive into their national legislation¹⁷. The EU RoHS requirements can be regarded as the reference for global market access of RoHS. However, each country might have different regulated product categories, documentation and information requirements. In countries like the U.S., where there are still no uniform RoHS regulations, state-level requirements, including substance restriction and reporting obligations, deserve special attention. Overall, the RoHS management is becoming stricter with expanded product scope and restricted substances. More countries are in the process of establishing or updating their RoHS regulations, e.g., Uzbekistan and Moldova. Producers should track the latest regulatory updates and get prepared for the specific national RoHS requirements to support compliance.

References