RoHSCalendar

EU RoHS Directive (2011/65/EU) Deadlines and compliance calendar

Put the real RoHS dates into your release calendar.

Track staged applicability, RoHS 3 phthalates dates, and exemption renewals as expiring risk.

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Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

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Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

RoHS is not a single deadline. It's a set of staged applicability dates, restricted-substance updates (notably the 4 RoHS 3 phthalates), and an exemptions lifecycle with strict renewal timing. This page turns those legal dates into calendar events your engineering, procurement, and compliance teams can run.

Section 1

The dates that drive RoHS planning (staged applicability)

RoHS applies by EEE category and, for certain categories, enters via staged dates. Treat these as first-placed-on-the-market gates: you should be able to prove compliance for any product shipped after the relevant date.

Use these dates to design your internal cutovers: supplier declaration collection, test triggers, and technical-file readiness.

By 2 January 2013: Member State transposition date (national rules live by this date)
3 January 2013: RoHS 1 repealed; RoHS 2 regime fully takes over
22 July 2014: medical devices enter RoHS (staged category applicability)
22 July 2016: in vitro diagnostic medical devices enter RoHS
22 July 2017: industrial monitoring and control instruments enter RoHS
22 July 2019: open scope (Category 11) and remaining EEE staged into scope

Section 2

RoHS 3 phthalates: schedule the 2019 and 2021 cutovers

Delegated Directive (EU) 2015/863 added four phthalates (DEHP, BBP, DBP, DIBP) to the restricted substances list (Annex II). The restrictions apply on different dates depending on the EEE category.

Operationally: plan a supplier re-declaration and targeted testing wave (cables, plastics, adhesives, elastomers) before each cutover, then enforce it as a change-control gate.

22 July 2019: phthalates restriction applies for most EEE
22 July 2021: phthalates restriction applies for medical devices and monitoring/control instruments (including industrial)
Spare parts / repair carve-outs can apply for equipment placed on the market before the relevant cutover date (2019 or 2021)

Section 3

Exemptions: renewal timing is a hard calendar constraint

Exemptions (Annex III and Annex IV) are time-limited and can expire or be narrowed. Treat them as expiring risk: if an exemption sunsets, you need a redesign path (substitution) or a renewal dossier.

RoHS sets concrete timing rules for renewal and for what happens if a renewal is rejected - these should be calendar events, not forgotten footnotes.

Renewal application must be submitted no later than 18 months before the exemption expires
If renewal is requested in time, the existing exemption remains valid until the Commission decision
The Commission states that an exemption decision currently takes about 18 to 24 months from the application date
If a renewal is rejected or an exemption is revoked, expiry is typically 12 - 18 months after the decision (plan redesign capacity accordingly)
Track validity periods by category: generally 5 years for categories 1 to 7, 10 and 11, and 7 years for categories 8 and 9

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Section 4

A release-ready compliance cadence (what to schedule every quarter)

RoHS compliance quality comes from repetition: make it part of release management. If you only do a one-time paper exercise, the next supplier change or BOM revision becomes a compliance incident.

Schedule recurring checkpoints to keep your evidence pack (supplier declarations, tests, exemption status, technical file) aligned with what you actually ship.

Quarterly: refresh exemptions register and check expiry / renewal status (especially for Annex III/IV)
Per release: enforce a material-change gate (new supplier / new material / new part -> declaration + test decision)
Monthly: reconcile declared homogeneous materials vs BOM/PLM; close evidence gaps
Annually: audit a sample of SKUs end-to-end (declaration -> test -> technical file -> DoC) for audit readiness

Section 5

Copy/paste calendar template (events to add for each product family)

Use relative timeboxes so teams can act before shipment. The goal is simple: you should never ship an EEE configuration whose RoHS status is unknown.

Adjust lead times for your supply chain realities (molded parts, cable harnesses, PCBAs, plastics).

T-120 days: supplier re-confirmation for plastics/cables + updated declarations requested
T-90 days: targeted testing decision (screening vs lab) for high-risk parts/material changes
T-60 days: exemption check (still valid? renewal pending? scope matches product use?)
T-30 days: technical file completeness check (EN IEC 63000-aligned index + traceable evidence)
T-0: ship gate - DoC and evidence pack retrievable within hours, not weeks

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