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FAQEU RoHS

What is a RoHS homogeneous material?

Under EU RoHS, restricted-substance concentration limits are checked by weight in each , not only across the finished product.

This FAQ helps decide what must be separated, tested, declared, or documented when a product contains plastics, metals, coatings, solders, adhesives, cables, or complex assemblies.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections7 primary sources
Overview

A RoHS is either one material of uniform composition throughout or a combination of materials that cannot be separated into different materials by such as unscrewing, cutting, crushing, grinding, or abrasive processes. That definition matters because Article 4 and Annex II apply RoHS by weight in homogeneous materials.

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5 of 5 questions
Question 1

RoHS homogeneous material definition

Directive 2011/65/EU defines a as one material of uniform composition throughout, or a material made from a combination of materials that cannot be disjointed or separated into different materials by .

The Directive's examples of include unscrewing, cutting, crushing, grinding, and abrasive processes. The test is not limited to non-destructive disassembly. If a mechanical action separates the item into different materials, assess each resulting against the applicable limit.

  • A single uncoated plastic part can be assessed as the plastic material, but a coated or overmoulded part may need separate material records for the base plastic and coating or attached material.
  • A cable is usually not one because conductors, insulation, shielding, fillers, jackets, and coatings may be mechanically separable.
  • A semiconductor package, connector, motor, power supply, or display should be broken into material-level evidence where separable metals, polymers, solders, platings, adhesives, and coatings create different RoHS risk points.

What is a under EU RoHS?

A is one material of uniform composition throughout, or a material made from a combination of materials that cannot be separated into different materials by such as unscrewing, cutting, crushing, grinding, or abrasive processes.

Are RoHS limits checked on the whole finished product?

No. RoHS Article 4 says no more than the Annex II maximum concentration value by weight in homogeneous materials is tolerated. A compliant-looking finished product can still fail if one separable material exceeds its applicable RoHS threshold.

Which RoHS thresholds apply at homogeneous-material level?

Annex II lists lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP at 0.1% by weight in homogeneous materials, and cadmium at 0.01% by weight in homogeneous materials.

Question 2

Annex II thresholds apply by material

The current consolidated Annex II lists ten restricted substances and their tolerated by weight in homogeneous materials. Cadmium has a lower threshold than the other listed substances.

For most listed RoHS substances, the Annex II limit is 0.1% by weight in the , equal to 1,000 mg/kg. Cadmium is limited to 0.01%, equal to 100 mg/kg.

  • 0.1% by weight (1,000 mg/kg): lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP).
  • 0.01% by weight (100 mg/kg): cadmium.
  • The four phthalates DEHP, BBP, DBP, and DIBP have specific application timing and carve-outs in Annex II for certain medical devices, monitoring and control instruments, cables, spare parts, and toys.
Question 3

How to split assemblies into RoHS materials

Start with the bill of materials, but do not stop at component names. RoHS evidence should map to the actual materials that can be separated or that remain inseparable after reasonable .

For a cable, that can mean separate evidence for copper or alloy conductors, plating, insulation, filler, shield, jacket, labels, and any coatings. For a printed circuit assembly, it can mean separate records for solder, component terminations, board laminate, component bodies, conformal coating, adhesives, and hardware.

  • Consider whether coatings, platings, paints, inks, adhesives, solders, sealants, and elastomers are distinct homogeneous materials. Assess additives within the polymer composition unless mechanical action separates different materials; the presence of an additive alone does not make it a separate .
  • Do not average a restricted substance across the mass of the finished product, the assembled component, or a whole cable when a separable material is the relevant assessment level.
  • When destructive separation is needed, document the method, sample identity, material fraction tested, and why the result maps to the RoHS material decision. If the laboratory cannot isolate a thin coating or another small material reliably, record the limitation instead of treating a mixed result as a definitive material-level pass.
Question 4

Evidence to keep for the homogeneous-material decision

A useful record is a material-level trail showing how the product was split, which Annex II threshold was applied, what declaration or test evidence supports the conclusion, and which exemptions or carve-outs were considered where relevant.

EN IEC 63000:2018 is the harmonised technical-documentation standard referenced for assessing materials, components, and electrical and electronic equipment under Directive 2011/65/EU. It is voluntary. If you use it, organize supplier declarations, test reports, risk assessment, and conformity records so they support the material-level conclusion. Record why the supplier information is sufficient or why testing is needed for each material assessed.

  • Keep a material breakdown tied to the product version, supplier, part number, and revision.
  • Record the applicable Annex II threshold for each material rather than a single product-level pass/fail statement.
  • Keep supplier declarations, IEC 62321 test reports where needed, exemption rationale, change-control records, and EN IEC 63000 technical documentation together with the EU declaration of conformity.
Recommended next step

Record the material-level RoHS decision

Map each product version to its separable materials, Annex II thresholds, supplier declarations, test reports, exemptions, and EN IEC 63000 technical documentation so reviewers can trace the RoHS decision without rebuilding the analysis.

Research workflow
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Talk through implementation

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Question 5

Common mistakes with homogeneous materials

The most common mistake is treating a supplier's broad product declaration as proof for every material in the part. That declaration may be useful, but it should still map to the homogeneous materials and Annex II thresholds that RoHS actually uses.

Another mistake is testing a mixed sample and treating the result as decisive when one high-risk separable material could be diluted by lower-risk material mass. If the legal question is material-level, the evidence should stay material-level.

  • Do not average lead in a solder joint across a whole circuit board or finished appliance.
  • Do not treat a plated metal part as a single material decision without considering whether the plating or coating needs separate evidence.
  • Do not reuse old material declarations after supplier, formulation, plating, coating, resin, recycled-content, or process changes without checking whether the RoHS material evidence still matches.
Primary sources

References and citations

IEC 62321-2:2021 sample preparation and disassembly
webstore.iec.ch4 citations
Referenced sections
  • IEC source for disassembly, disjointment, mechanical sample preparation, and sampling strategies before analytical testing.
  • IEC 62321-2 supports the practical disassembly, disjointment, and mechanical sample-preparation context for material-level testing.
  • IEC 62321-2 describes sampling strategies and mechanical preparation of samples from electrotechnical products before analytical testing.
Show 1 more
  • Supports attention to sampling and mechanical preparation before substance testing.
"mechanical preparation of samples"
More quoted passages
"Disassembly, disjointment and mechanical sample preparation"
"strategies of sampling"
"preparing samples prior to the determination"
Commission Implementing Decision (EU) 2020/659 on EN IEC 63000
data.europa.eu2 citations
Referenced sections
  • Official source for EN IEC 63000:2018 as the harmonised RoHS technical-documentation standard.
  • Official source for EN IEC 63000:2018 as the harmonised standard for RoHS technical documentation.
"EN IEC 63000:2018"
More quoted passages
"technical documentation required for assessing materials"
Directive 2011/65/EU on restriction of hazardous substances (consolidated version)
eur-lex.europa.eu2 citations
Referenced sections
  • Primary legal source for the homogeneous-material definition, Article 4 concentration rule, and Annex II restricted substances and thresholds.
  • Article 3(20) gives the legal definition of homogeneous material and lists the mechanical actions used to test separability.
"by weight in homogeneous materials"
More quoted passages
"one material of uniform composition throughout"
Directive 2011/65/EU manufacturer obligations
eur-lex.europa.eu
Referenced sections
  • Article 7 requires manufacturers to draw up technical documentation and carry out internal production control.
"draw up the required technical documentation"

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