RoHS 3 // Annex II + Annex III/IV

RoHS 3 substance compliance checker — EEE thresholds, exemptions, CE / UKCA marking

Check a homogeneous-material concentration against Directive 2011/65/EU as amended by 2015/863. Verdict (PASS / FAIL / EXEMPT) with Annex III/IV exemption lookup, GB / EU / US jurisdictional split, and a cited compliance audit trail your SMB technical file can keep for the mandatory 10 years.

Dataset verified: 2026-06-12 · Methodology reviewed: 2026-06-12

The short answer (reviewed 2026-06-12): RoHS 3 restricts 10 substances in electrical & electronic equipment. The limit is 0.1% by weight (1,000 ppm) in any homogeneous material for lead, mercury, hexavalent chromium, PBB, PBDE and the four phthalates (DEHP, BBP, DBP, DIBP), and a stricter 0.01% (100 ppm) for cadmium. An over-limit value is a FAIL unless the specific material falls inside a narrow Annex III/IV exemption — and this tool only ever offers an exemption as a candidate for you to confirm, never as an automatic “exempt” verdict.

Sources: Directive 2011/65/EU Annex II (EUR-Lex) · Delegated Directive (EU) 2015/863 · European Commission RoHS

Laptops, routers, mobile phones

Always the homogeneous material level (Art. 4(1) Dir. 2011/65/EU). Never the whole assembly.

PASS
CE
950/1,000 ppm(0.1% homogeneous material)
  • [Annex II — Dir. 2011/65/EU]
  • [Candidate exemption 6(c) — Annex III, exp. 2027-06-30]
  • [Marking: CE]

Indicative compliance check based on Directive 2011/65/EU as amended (RoHS 3 phthalate addition, Delegated Directive (EU) 2015/863). Not legal advice. Verify exemption status at the official sources before placing product on market.

Primary sources

RoHS 3 substance compliance result

Homogeneous material — the load-bearing definition

RoHS thresholds apply at the homogeneous-material level, not the part or product level. A homogeneous material is one of uniform composition throughout that cannot be mechanically separated into different materials. SMB sourcing managers routinely conflate "part" with "homogeneous material"; XRF tests at the part level routinely under-report substance concentration.

Recordkeeping window — 10 years

Article 7(b) of Directive 2011/65/EU requires the technical documentation and EU Declaration of Conformity to be retained for 10 years after market placement. Manufacturers should link BOM, component declarations, and conformity assessment records to the corresponding DoC and keep them all for the same 10-year window.

GB / EU / US jurisdictional split

GB RoHS (SI 2012/3032) diverged from EU RoHS after IP completion day (31 Dec 2020). EU exemption amendments published after that date are not automatically incorporated into GB. Northern Ireland continues to follow EU RoHS under the Windsor Framework (CE + UKNI marking). The US has no federal RoHS analogue — California has a narrower parallel rule via the Electronic Waste Recycling Act 2003.

Frequently asked questions

How many substances does RoHS 3 restrict, and at what level?

Ten. The original RoHS 2 six (lead, mercury, cadmium, hexavalent chromium, PBB, PBDE) plus the four phthalates (DEHP, BBP, DBP, DIBP) added by Delegated Directive (EU) 2015/863. The threshold is measured at the homogeneous-material level: 0.1% (1,000 ppm) for every substance except cadmium, which is the stricter 0.01% (100 ppm).

What does 'homogeneous material' actually mean?

A material of uniform composition throughout that cannot be mechanically separated into different materials. The limit applies to that material, NOT the part or the finished product. A solder joint, a plastic housing and a coating are each separate homogeneous materials. Part-level XRF readings routinely under-report concentration because they average across several materials.

If my value is over the limit but an exemption exists, am I compliant?

Not automatically. Every Annex III/IV exemption is scoped to a very specific material or application (lead alloyed into copper, lead in high-melting solder, a glass/ceramic dielectric, an ink applied as enamel on glass, a recovered medical-device spare part…). This tool shows you the candidate exemption and its scope, but you must confirm your material is genuinely in scope. If it is not, the verdict is a plain FAIL.

How long do exemptions last, and how do I know if one expired?

Annex III/IV exemptions are time-limited and renewed on a rolling cycle; a renewal application must be filed 18 months before expiry (Article 5(5)). Some entries have already lapsed — e.g. the original combined Pb+Cd printing-ink entry 21 expired 21 July 2024. This tool never offers an expired entry as a candidate and shows each entry’s expiry date.

Does RoHS apply the same way in Great Britain and the US?

No. GB RoHS (SI 2012/3032) diverged from EU RoHS after IP completion day (31 Dec 2020), so EU exemption amendments published afterwards are not automatically incorporated. Northern Ireland still follows EU RoHS under the Windsor Framework. The US has no federal RoHS analogue; California’s Electronic Waste Recycling Act 2003 is a narrower parallel rule, so this tool returns “no federal rule” for the US rather than fabricating a threshold.

How long must I keep RoHS conformity records?

The technical documentation and EU Declaration of Conformity must be kept for 10 years after the product is placed on the market (Article 7(b) of Directive 2011/65/EU). Link your BOM, component declarations and conformity assessment to the corresponding DoC and retain them for the same window.

Is this checker legal advice?

No. It is an indicative compliance check derived from the cited regulations and a versioned dataset. Exemption applicability and marking guidance can change and must be verified against the official Annex III/IV register and a qualified compliance professional before placing a product on the market.