Artifact GuideEU RoHS

RoHS Homogeneous Material Thresholds

EU RoHS concentration limits are checked by weight in each homogeneous material, not by averaging across the finished electrical or electronic product.

This guide helps split assemblies into material decisions, apply the Annex II limits, and keep evidence that maps declarations or tests to the actual RoHS assessment level.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
10

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

Under Directive 2011/65/EU, the RoHS restricted-substance limits are tolerated by weight in each , not by averaging across the finished EEE. A product, assembly, cable, connector, coating, solder joint, adhesive, or plastic part must therefore be split at the level that can or cannot be mechanically separated.

Section 1

What the homogeneous-material threshold means

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 separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding, or abrasive processes.

Article 4 applies the Annex II maximum concentration values by weight in homogeneous materials. Do not average a restricted substance across a whole product, populated board, cable, motor, display, or connector when a separable material is the relevant RoHS unit. The test asks whether the materials can be disjointed by mechanical action, not whether separation is convenient, economical, or part of normal product use.

  • Start with the bill of materials, then identify the metals, plastics, solders, coatings, platings, elastomers, adhesives, inks, labels, fillers, and jackets that may need separate evidence.
  • Use mechanical separability as the boundary test: if the material can be separated by the listed mechanical actions, assess the separated material rather than the larger assembly.
  • Keep the material split tied to product version, supplier, part number, material grade, coating or plating specification, and revision so later changes do not silently invalidate the RoHS record.
Sources for this answer
Directive 2011/65/EU on restriction of hazardous substances (consolidated version)
Current legal text as of 1 July 2026 for the Article 3(20) homogeneous-material definition and Article 4(2) concentration rule.
European Commission RoHS FAQ guidance
Commission FAQ explaining that maximum concentration values apply to each homogeneous material individually.
Section 2

Annex II concentration limits

Annex II currently lists ten restricted substances and the maximum concentration values tolerated by weight in homogeneous materials. Cadmium has the lower limit; the other listed substances are set at 0.1% by weight.

For material reviews, record the exact substance and threshold that applies. The 0.1% limit equals 1,000 mg/kg and the 0.01% cadmium limit equals 100 mg/kg, but keep the legal percentage in the conformity record and confirm that any laboratory unit conversion uses the same material basis.

  • 0.1% by weight: lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), DEHP, BBP, DBP, and DIBP.
  • 0.01% by weight: cadmium.
  • The four phthalates DEHP, BBP, DBP, and DIBP have Annex II timing and carve-outs for certain medical devices, monitoring and control instruments, cables, spare parts, and toys, so do not treat phthalate scope as a generic 0.1% rule without checking the product context.
Sources for this answer
Directive 2011/65/EU Annex II restricted substances
Current Annex II lists the restricted substances and their maximum concentration values by weight in homogeneous materials.
Commission Delegated Directive (EU) 2015/863 adding phthalates to RoHS Annex II
Binding source for adding DEHP, BBP, DBP, and DIBP to Annex II.
Section 3

How to apply the limits to assemblies, coatings, and samples

A product can look compliant at total-product level while one material fails at homogeneous-material level. Build the RoHS evidence from the relevant material fractions: the solder in a joint, the copper or alloy conductor in a cable, the insulation compound, a surface coating, a connector plating, or the polymer body of a component.

Sampling and testing decisions should avoid dilution. If a mixed sample combines high-risk and low-risk materials, the result may not answer the RoHS question for a mechanically separable material or distinct coating. Record the sample boundary, preparation method, method capability, reporting limit, and which the result represents.

  • For cables, consider conductor metal, plating, insulation, shielding, fillers, labels, jackets, and coatings as separate possible evidence lines.
  • For printed circuit assemblies, consider solder, board laminate, component bodies, terminations, conformal coating, adhesives, fasteners, and plated or coated metal parts.
  • For coatings and platings, document the layer or substrate assessed, what sample preparation was used, and how the result maps back to the RoHS threshold.
  • Treat screening and confirmatory analysis as different evidence states. A screening result that cannot resolve the regulated species or reporting limit needs a documented follow-up method before it can support the final conclusion.
Sources for this answer
Directive 2011/65/EU homogeneous material definition
Current Article 3(20) defines homogeneous material through uniform composition and mechanical separation.
European Commission RoHS FAQ guidance
Commission FAQ gives examples such as plastic covers, copper wire, solder joints, and cautions against sample dilution.
IEC 62321-2:2021 sample preparation and disassembly
IEC source for sampling strategies, disassembly, disjointment, and mechanical sample preparation before analytical testing.
IEC 62321-3-1:2013 XRF screening
IEC publisher source for XRF screening of lead, mercury, cadmium, total chromium, and total bromine, supporting the distinction between screening results and substance-specific conclusions.
Section 4

Evidence to keep for threshold decisions

A reviewable RoHS file shows the chain from product scope to material split, Annex II threshold, supplier evidence, test evidence where needed, exemption rationale, and final declaration. The evidence should let a reviewer see why each material was accepted without rebuilding the engineering history.

EN IEC 63000:2018 is the cited harmonised standard for technical documentation used to assess materials, components, and electrical and electronic equipment under Directive 2011/65/EU. Use it to organise supplier declarations, test reports, risk assessment, and conformity documentation, while keeping the product-specific material decisions and unresolved evidence gaps visible.

  • Keep a material-level restricted-substance matrix showing each , applicable threshold, evidence type, source date, supplier or lab, and any exemption relied on.
  • Attach declarations or test reports to the specific part, material, coating, plating, formulation, supplier, and revision they support.
  • Reopen the assessment after supplier changes, material substitutions, plating or coating changes, recycled-content changes, new exemptions or expiry dates, or updates to harmonised standards.
Sources for this answer
Commission Implementing Decision (EU) 2020/659 on EN IEC 63000
Official source for EN IEC 63000:2018 as the harmonised RoHS technical-documentation standard.
Directive 2011/65/EU manufacturer obligations
Current Article 7 requires manufacturers to draw up technical documentation and carry out internal production control.
European Commission RoHS Directive implementation
Commission implementation page for RoHS exemptions and renewal context.
Recommended next step

Turn material-level RoHS evidence into a reusable file

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
Open Research Copilot

Answer RoHS scope, threshold, exemption, and evidence questions with cited outputs.

Explore next step
Talk to Sorena
Talk through RoHS implementation

Review your material split, evidence model, supplier controls, and next actions.

Explore next step
Primary sources

References and citations

European Commission RoHS FAQ guidance
environment.ec.europa.eu
Referenced sections
  • Commission FAQ gives examples such as plastic covers, copper wire, solder joints, and cautions against sample dilution.
"homogeneous materials are adequately separated"
IEC 62321-3-1:2013 XRF screening
webstore.iec.ch
Referenced sections
  • IEC publisher source for XRF screening of lead, mercury, cadmium, total chromium, and total bromine, supporting the distinction between screening results and substance-specific conclusions.
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