RoHS 3

RoHS 3: What You Should Know About EEE Restricted Materials

RoHS 3 is the most recent update of the European Union (EU) directive that limits the use of particular hazardous substances in electrical and electronic equipment (EEE). The term RoHS stands for Restriction of Hazardous Substances, and its objective is to safeguard human health and the environment from the potential risks caused by EEE waste. RoHS 3 became effective on July 22, 2019, and it included four new materials to the list of restricted substances and a new product category. In this article, we will explain the meaning of RoHS 3, why it is critical, how to adhere to it, and address some frequently asked questions.

What is RoHS 3?

RoHS 3 is the informal name of Directive 2015/863/EU, which amended the original RoHS directive (Directive 2011/65/EU) by adding four new substances to the list of restricted materials. These substances include:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Plasticizers are additives used to increase the flexibility and durability of plastics. These substances are mainly used for this purpose. However, they pose serious threats to human health and the environment. Therefore, they are listed on the REACH list of Substances of Very High Concern (SVHC). 

The maximum concentration limit for these substances is 0.1% by weight in homogeneous materials. Homogeneous materials are those that cannot be mechanically separated into different materials. This limit applies to each substance rather than the total amount of all four substances.

RoHS 3 has expanded the directive’s scope by including a new product category, Category 11. This category covers all other electrical and electronic equipment (EEE) not included in the other categories. Some examples of products that fall under this category are two-wheeled vehicles, electronic nicotine delivery systems (e-cigarettes, vape pens, etc.), cannabis vaporizers, and electrical cables with a working voltage below 250V.

These products must comply with the same restrictions as the other categories, except for medical devices and monitoring and control instruments, which have a two-year extension until July 22, 2021.

Why is RoHS 3 important?

RoHS 3 is important because it helps to reduce the negative impacts of EEE waste on human health and the environment. EEE waste is one of the fastest-growing waste streams in the world, and it contains many hazardous substances that can leach into soil and water or release toxic emissions when incinerated. These substances can cause various health problems, such as cancer, reproductive disorders, neurological damage, and endocrine disruption.

By restricting the use of these substances in EEE products, RoHS 3 aims to prevent their accumulation in EEE waste and facilitate their recycling and disposal. This can help protect workers involved in EEE production and waste management, consumers who use EEE products, and the general public who may be exposed to EEE waste.

RoHS 3 is crucial in harmonizing the EU market and promoting fair competition among EEE manufacturers and suppliers. By adhering to RoHS 3 regulations, EEE products can gain entry into the EU market and other regions with similar regulations, enhancing customer trust and satisfaction. Moreover, it can encourage innovation and quality improvement.

How to comply with RoHS 3?

To comply with RoHS 3, EEE manufacturers, authorized representatives, importers, and distributors must ensure that their products meet the directive’s requirements and do not contain more than the restricted substances. They must also provide technical documentation and declarations of conformity to demonstrate their compliance.

To verify their compliance, they can use various methods, including Testing, Inspection and Auditing.


The testing process involves subjecting a product or material to a stimulus or condition to assess its response or behavior. Testing can be conducted in either or field settings using various equipment and methods. By performing tests, various features of a product or material can be evaluated, including functionality, durability, reliability, safety, and compatibility.


Examining a product or material to ensure it meets specific standards or specifications is known as inspection. Inspection can be performed manually or automatically with various devices or systems. It can take place at different stages of production or before shipment.


One common practice is to assess a product or process to ensure it meets all necessary regulations and requirements. This type of evaluation, called auditing, is often conducted by certified professionals either within or outside of the organization. Auditing may encompass various factors, including design, development, production, documentation, and management.

To ensure reliable and accurate results, these methods should be performed by independent and professional third-party service providers, such as VIS. VIS Quality Control can help EEE manufacturers and suppliers with RoHS 3 testing, inspection, and auditing services, as well as provide guidance and support throughout the compliance process.

Common questions about RoHS 3

What is the difference between RoHS 2 and RoHS 3?

RoHS 2 is the previous version of the directive, which came into effect in 2011. RoHS 3 is the latest update of the directive, which came into effect in 2019. The main difference between them is that RoHS 3 added four new substances to the list of restricted materials and a new product category to the directive’s scope.

What is the difference between RoHS and REACH?

RoHS and REACH are EU regulations that protect human health and the environment from hazardous substances. However, they have different scopes and objectives. RoHS focuses on restricting the use of certain substances in EEE products. In contrast, REACH focuses on registering, evaluating, authorizing, and restricting the use of all chemical substances in the EU market.

 How can I prove that my product is RoHS 3 compliant?

You can prove that your product is RoHS 3 compliant by providing technical documentation and declarations of conformity that show that your product meets the directive’s requirements. You can also use third-party testing, inspection, and auditing services to verify your compliance and obtain certificates or reports that confirm your compliance.

What are the penalties for non-compliance with RoHS 3?

The penalties for non-compliance with RoHS 3 vary depending on the country or region where the product is sold or used. However, they can include fines, product recalls, bans, or legal actions. Non-compliance can also damage your reputation and customer trust, as well as result in loss of sales and revenue.


If you’re an EEE manufacturer or supplier and want to ensure your products meet the EU’s RoHS 3 directive, VIS Quality Control can help! We provide testing, inspection, and auditing services, as well as guidance and support throughout the compliance process. Don’t risk the health and safety of your customers or the environment – contact us today to learn more about how we can help you achieve RoHS 3 compliance.

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