Important Note: RoHS 3.0 is not a brand new standalone EU directive. It is an industry nickname. The core official directive remains 2011/65/EU (RoHS 2.0). RoHS 3.0 refers merely to its amending delegated act. RoHS stands for the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment, a mandatory EU environmental regulation for market access of electrical and electronic products.
I. Comparison Table of Three RoHS Versions
|
Version |
Legal Reference |
Core Description |
Enforcement Date |
Controlled Substances |
|
RoHS 1.0 |
2002/95/EC |
The original RoHS that established the foundational framework. Only 6 hazardous substances were restricted. No mandatory CE marking, no full technical documentation requirements, narrower product scope. |
01 07 2006 |
6 substances: Lead, Mercury, Cadmium, Hexavalent Chromium, PBBs, PBDEs |
|
RoHS 2.0 (Recast) |
2011/65/EU |
Repealed the old RoHS 1.0. Incorporated into the CE marking system. Requires technical documentation and Declaration of Conformity (DoC). Expanded product coverage to include medical devices and industrial monitoring instruments. Established exemption rules, market surveillance and liability mechanisms. The substance list remained 6 items. |
02 01 2013 |
6 substances (same as RoHS 1.0) |
|
RoHS 3.0 |
Amending Act (EU) 2015/863 |
Supplement to Annex II of RoHS 2.0. Not an independent new directive. On top of the original 6 substances, 4 phthalates (DEHP, BBP, DBP, DIBP) were added, bringing the total controlled substances to 10. |
22 07 2019 |
10 substances (6 heavy metals + 4 phthalates) |
Practical compliance reminder: For exports to the EU today, products must comply with the RoHS 2.0 base directive plus the (EU) 2015/863 amendment (commonly known as RoHS 3.0). This means RoHS 10 item testing is required. Testing only for the original 6 substances no longer meets current EU regulatory requirements.
II. Logical Relationship Between the Three Versions
RoHS 1.0 (2002/95/EC) has been fully repealed and is invalid. It cannot serve as compliance evidence for EU exports. RoHS 2.0 (2011/65/EU) is the legal foundation, establishing the full regime covering CE marking, documentation, market surveillance and product scope. RoHS 3.0 [(EU) 2015/863] = patch revision to RoHS 2.0. It does not alter the institutional framework; it only adds 4 restricted phthalate substances.
Simplified analogy: RoHS 2.0 is the operating system itself, and RoHS 3.0 is a major update patch. The formal legal wording is: Directive 2011/65/EU as amended by (EU) 2015/863.
III. Two Easily Confused Key Points
- RoHS 3.0 ≠ future RoHS proposal Some online sources claim RoHS 3.0 will add TBBP A, MCCP and other substances. These are only pending future revision proposals from the EU. As of 2026, they have not been formally enacted into law and are not mandatory requirements under current RoHS 3.0. They cannot be used as testing criteria.
- Distinguish EU RoHS from China RoHS China RoHS: GB 26572 2025, mandatory enforcement starting 01 08 2027. It also controls 10 hazardous substances and benchmarks EU RoHS 3.0. However, it is a Chinese national standard and is not equivalent to EU RoHS. China RoHS test reports cannot be directly used as EU compliance proof for exports to the EU.
IV. Practical Guidance for Enterprises
When exporting electrical and electronic products to the EU, 6 item RoHS testing is no longer acceptable; 10 item RoHS testing is mandatory. Supplier declarations of conformity and test reports should state compliance with 2011/65/EU and the amending directive (EU) 2015/863. Avoid simply writing “RoHS3.0”, as this is only an industry nickname and not official terminology.
RoHS compliance means more than just laboratory testing. Under the RoHS 2.0 framework, the following are also required: CE marking, technical documentation, Declaration of Conformity (DoC), supply chain control, and record retention for 10 years.
