Restriction of Hazardous Substances Directive (RoHS) Compliance Services

The EU RoHS Directive 2011/65/EU restricts the use of certain harmful substances in electrical and electronic equipment such as:

• Large and small household appliances.
• IT and telecommunications equipment.
• Consumer equipment.
• Lighting equipment.
• Electrical and electronic tools.
• Toys, leisure and sports equipment.
• Medical devices.
• Monitoring and control instruments, including industrial monitoring and control instruments.
• Automatic dispensers.
• Other electrical and electronic equipment not covered by any of the categories above.

The hazardous substances restricted by the EU RoHS are:

• Lead
• Mercury
• Cadmium
• Hexavalent chromium
• Polybrominated biphenyls (PBB)
• Polybrominated diphenyl ethers (PBDE)
• Phthalates: DEHP – BBP – DBP – DIBP added with the amendment 2015/863

These substances can be evaluated using specific test methods that have been developed by the International Electrotechnical Commission (IEC) and that are part of the IEC 62321 – Determination of certain substances in electrotechnical products series of standards.

The EU RoHS Directive also requires that before placing an electrical or electronic equipment (EEE) product into the European market, a manufacturer, importer or retailer must be sure that the appropriate conformity assessment procedure has been performed and is in line with the EN IEC 63000:2018 standard, which became mandatory in 2021.

In addition, the EU RoHS Directive requests manufacturers to draw up technical documentation. And, where compliance of EEE with the applicable requirements has been demonstrated, manufacturers must draw up an EU declaration of conformity and affix the CE marking on the finished product.

Non-compliance with EU RoHS Directive may result in notification via the Safety Gate, the EU rapid alert system for dangerous non-food products.

Our portfolio of chemical management services helps global manufacturers, importers and retailers of electrical and electronic products to evaluate compliance with the EU RoHS Directive.

In 2017, United Arab Emirates issued the UAE RoHS regulation that restricted the presence of similar hazardous substances as the one requested by EU RoHS for all electrical and electronic equipment.

In order to import these articles into United Arab Emirates, manufacturers and retailers must obtain a Certificate of Conformity under the RoHS Regulation, with two possible different Conformity Assessment processes:

• Emirates Conformity Assessment Scheme (ECAS).
• Emirates Quality Mark (EQM).

Our portfolio of services can help you evaluate compliance with the UAE RoHS. We are also offering support for technical file documentation, product certification and trainings.

In addition, Underwriters Laboratories Middle East FZ-LLC is an approved Conformity Assessment Body for UAE and can provide both ECAS and EQM certificates.

We also perform testing through our ISO/IEC 17025 accredited laboratories.

On July 9, 2021, the Saudi Standards, Metrology and Quality Organization (SASO) published the Technical Regulations for Limiting Hazardous Substances in Electrical and Electronic Appliances and Equipment with an effective implementation date six months after publication, on Jan. 5, 2022.

However, SASO communicated the postponement of the implementation on Dec. 16, 2021.

SASO Board approved the gradual implementation of the regulation by category.

All products in scope of the new regulation will require a certificate of conformity according to the certification module TYPE A1 of the ISO/IEC 17067. The evaluation must be done by one of the Notified Bodies approved by SASO. RoHS technical evaluation will be required to obtain the Product Certification of Conformity (PcoC) under the main regulation. In order to obtain the final CoC and be ready to access the market, the manufacturers need to comply with all the applicable regulations on their products, not only RoHS but also safety, EE and other.

Suppliers will need to apply for RoHS PcoC through the SABER platform. RoHS Technical Documentation and Certification will be required as a preliminary step to obtain the Product CoC under the main product regulation.

UL Solutions has multiple Conformity Assessment Bodies for SASO RoHS (UL LLC, UL International Italia S.r.l, UL-CCIC Company Limited, Underwriters Laboratories Middle East FZ-LLC) and can provide PcoC certifications. Additionally, UL Solutions has global laboratories that can perform RoHS testing through its accredited laboratories.

The following states have regulations that follow the European Union’s RoHS Directive model: California, Connecticut, Florida, Hawaii, Iowa, Maine, Maryland, Michigan, Minnesota, New Hampshire, New Mexico, New York, Rhode Island, Vermont, Virginia, and Washington.

Many of these states prohibit the sale of electronic devices that are not approved for sale in the European Union based on the RoHS directive. This means that if one or more of the heavy metals exceeds a specific total concentration, it cannot be sold in that state.

An example of the California RoHS regulation follows.

The California Electronic Waste Recycling Act (SB20 and its Amendment SB50), issued in 2003, stipulates the requirements for restricted substances (lead, mercury, cadmium and hexavalent chromium) in video display devices, regulating nine categories of specific electronic equipment with the screen diagonal length greater than four inches, including manufacturer-refurbished products for retail:

• Cathode ray tubes (CRTs)
• Cathode ray tube containing devices (CRT devices)
• Computer monitors containing CRTs
• Laptop computers with liquid crystal display (LCD)
• Desktop monitors containing LCDs
• Televisions containing CRTs
• Televisions containing LCD screens
• Plasma televisions
• Portable DVD players with LCD screens
• OLED-containing televisions, laptop computers, tablets and desktop monitors*
• LCD-containing tablets and displays*  

*Added in 2021 under the Emergency Rulemaking package

China’s Restriction of Hazardous Substances (China RoHS) is regulated under the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products. China RoHS applies to a broad range of electrical and electronic products. It restricts the use of  hazardous substances, aligned with the European Union RoHS Directive, including:

• Lead
• Mercury
• Cadmium
• Hexavalent chromium
• Polybrominated biphenyls (PBB)
• Polybrominated diphenyl ethers (PBDE)
• Phthalates: Bis(2-ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), Diisobutyl phthalate  (DIBP)

To comply with China RoHS, manufacturers and importers must use compliant labeling, include the proper disclosure of hazardous substances and demonstrate conformity with applicable product catalog requirements. The electrical and electronic products included in the “Compliance Management Catalog” should choose either the nationally promoted voluntary certification or self-declaration method to complete the conformity assessment for the restriction of hazardous substances in electrical and electronic products.

China RoHS mandates specific labeling requirements. Products must be marked with the Environmental Protection Use Period (EPUP) logo and have clear information about whether they contain any of the restricted substances above the threshold. A table of the present toxic and hazardous substances must be provided with the product, indicating the parts that contain these substances and their concentrations.

From Aug. 1, 2027, the conformity assessment activities shall be done in accordance with GB 26572-2025 only. Products that have completed conformity assessment in accordance with GB/T 26572-2011 and its amendment No. 1 before this date and continue to be manufactured or imported may complete the transition to conformity assessment under GB 26572-2025 through natural transition methods (such as certificate renewal upon expiration or product modification).

UL Solutions supports manufacturers, importers and retailers in understanding China RoHS labeling obligations, hazardous substance requirements and third‑party testing needs. Our laboratories in China have China National Accreditation Service for Conformity Assessment (CNAS) and China Metrology Accreditation (CMA) accreditation for China RoHS testing.