FAQEU

RoHS FAQ EU RoHS 0.1% and 0.01% Substance Limits

EU RoHS Annex II sets maximum concentration values by weight in homogeneous materials, not as an average across the finished electrical or electronic product.

Use this FAQ to separate the 0.1% limits from cadmium's 0.01% limit and record the material-level evidence behind the conclusion.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
4

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Primary sources
5

Cited legal and guidance references.

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Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Under EU RoHS, the 0.1% and 0.01% values are maximum concentration values by weight in each homogeneous material. Lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP are listed at 0.1%; cadmium is listed at 0.01%. A product-level average is not enough unless every relevant homogeneous material is within the applicable limit or a valid exemption applies.

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4 of 4 questions
Question 1

What do the 0.1% and 0.01% substance limits mean under EU RoHS?

Article 4 of Directive 2011/65/EU points to Annex II for the maximum concentration values tolerated by weight in homogeneous materials. That means the threshold is checked against each separable material, coating, solder, plastic, alloy, wire, or other homogeneous material, not against the finished product as a whole.

The practical split is simple but easy to misapply: cadmium has the tighter 0.01% limit; the other Annex II substances are listed at 0.1%. The four phthalates added by Delegated Directive (EU) 2015/863, DEHP, BBP, DBP, and DIBP, also sit at 0.1% in Annex II.

  • Use 0.1% by weight for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP.
  • Use 0.01% by weight for cadmium.
  • Apply the value to each homogeneous material separately; do not dilute a restricted substance by averaging it across an assembly, component, or finished EEE.
  • If an Annex III or Annex IV exemption is used, record the exact exemption entry, product category, substance, material, and validity condition that makes the higher concentration acceptable.
Citations
Question 2

What evidence should be kept for RoHS 0.1% and 0.01% limits?

Evidence should let a reviewer trace the conclusion from the finished EEE down to the homogeneous materials that matter for Annex II. A supplier statement that only says "RoHS compliant" is weak if it does not identify covered parts, materials, substances, exemptions, or the basis for the declaration.

The technical file should connect the BOM, homogeneous-material list, material declarations, substance risk assessment, selected test reports, exemption register, EU declaration of conformity, and change-control history. Manufacturers must keep the technical documentation and EU declaration of conformity for 10 years after the EEE has been placed on the market.

  • Map each relevant homogeneous material to the applicable Annex II substance and limit: 0.01% for cadmium or 0.1% for the other listed substances.
  • Keep supplier declarations specific to the part, material, revision, and restricted substances they cover.
  • When testing is used, retain the sample description, preparation logic, test method, lab report, and the material-level result being compared with the Annex II threshold.
  • For exemptions, retain the Annex III or Annex IV entry, applicability category, expiry or renewal status, and the product/material facts that support use of the exemption.
  • Recheck the record after material changes, supplier changes, product redesign, exemption changes, or a change to the harmonised standard used for the technical documentation.
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Check RoHS limits at material level

Use the 0.1% and 0.01% split to review BOM materials, supplier declarations, test reports, exemptions, and the technical documentation behind CE marking.

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Question 3

How to apply the RoHS 0.1% and 0.01% limits

Use the limits as a material-level screening question before release, supplier approval, design change, or exemption review. The output should be a clear pass, exemption-supported, or nonconforming-material decision for each material-substance pair.

  • Identify the EEE, category, part number, supplier, revision, and date of placing on the market.
  • Break the relevant assemblies into homogeneous materials, including plastics, metals, coatings, solder, insulation, cables, and phthalate-relevant polymer parts.
  • For each homogeneous material, mark whether cadmium, lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, or DIBP is relevant.
  • Compare cadmium results or declarations to 0.01% by weight and all other Annex II substance results or declarations to 0.1% by weight.
  • If a value exceeds the Annex II limit, stop treating the material as compliant unless an exact Annex III or Annex IV exemption covers that use.
  • Store the conclusion in the RoHS technical documentation package used to support the CE marking and EU declaration of conformity.
Citations
Question 4

Common mistakes to avoid when documenting EU RoHS 0.1% and 0.01% substance limits

Most mistakes come from using the right percentage at the wrong level of detail. Annex II limits are material-level values, so a finished-product calculation can hide a nonconforming coating, solder, plastic, or cable material.

  • Do not apply 0.1% to cadmium; Annex II lists cadmium at 0.01%.
  • Do not average a restricted substance across a component or finished EEE when separable homogeneous materials should be checked individually.
  • Do not forget DEHP, BBP, DBP, and DIBP when reviewing phthalate-relevant polymers; they are listed in Annex II at 0.1%.
  • Do not rely on an exemption unless the exact material use, product category, and exemption timing still match Annex III or Annex IV.
  • Do not reuse supplier declarations after a material, coating, cable, adhesive, solder, or supplier revision changes unless the declaration still covers the changed material.
Citations
Primary sources

References and citations

European Commission - harmonised standards overview
single-market-economy.ec.europa.eu
Referenced sections
  • Official Commission overview for how harmonised standards and OJEU references support EU product-law conformity assessments.
"Harmonised standards are European standards adopted on the basis of a request."
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