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.

Use this guide to 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

May 9, 2026

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Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated May 9, 2026

Overview

Under Directive 2011/65/EU, the RoHS restricted-substance limits are tolerated by weight in homogeneous materials. That means a finished product, assembly, cable, connector, coating, solder joint, adhesive, or plastic part has to be assessed at the material level that can or cannot be mechanically separated.

Section 1

What the homogeneous-material threshold means

Directive 2011/65/EU defines a homogeneous material 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 then applies the Annex II maximum concentration values by weight in homogeneous materials. The practical consequence is simple: 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.

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)

Primary legal source 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. A single RoHS pass statement is weaker than a material-level matrix showing which homogeneous material was assessed against which Annex II limit.

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

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. That is why RoHS evidence should be built from the material fractions that matter: 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 the material that can be mechanically separated or that remains a distinct coating or layer.

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 whether the layer is treated as a separate material question, what sample preparation was used, and how the result maps back to the RoHS threshold.

Sources for this answer

Directive 2011/65/EU homogeneous material definition

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.

Section 4

Evidence to keep for threshold decisions

The strongest 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 harmonised standard referenced for technical documentation for assessing materials, components, and electrical and electronic equipment under Directive 2011/65/EU. Use it as the organizing frame for supplier declarations, test reports, risk assessment, and conformity documentation.

Keep a material-level restricted-substance matrix showing each homogeneous material, 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

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.

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Talk to Sorena

Talk through RoHS implementation

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

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Primary sources