EU RoHS Directive Timeline

Directive 2011/65/EU was adopted on 8 June 2011, published on 1 July 2011, and entered into force on 21 July 2011. Member States had to transpose it by 2 January 2013, and the earlier Directive 2002/95/EC was repealed from 3 January 2013. Those dates establish the RoHS 2 framework; they do not replace the later category-specific application dates in Article 4.

The wider RoHS timeline can also include standards, Commission guidance, consultations, review findings, and proposed changes. Label them by legal status. A delegated directive changes an annex after the required national implementation; Commission guidance explains the Commission's approach without replacing the Directive; a consultation or proposal does not create an operative product duty.

Article 4 phased in medical devices and monitoring and control instruments from 22 July 2014, in vitro diagnostic medical devices from 22 July 2016, industrial monitoring and control instruments from 22 July 2017, and other formerly out-of-scope EEE from 22 July 2019. These dates apply to EEE placed on the market from the relevant date; they do not recur each year.

Delegated Directive (EU) 2015/863 added DEHP, BBP, DBP, and DIBP to Annex II. Member States applied the amendment from 22 July 2019. The four restrictions apply to medical devices, including in vitro medical devices, and monitoring and control instruments, including industrial instruments, from 22 July 2021. They do not apply to specified cables and spare parts for EEE placed before the applicable 2019 or 2021 date. DEHP, BBP, and DBP in toys remain under the referenced REACH restriction.

An exemption's printed expiry date is not enough to determine status. Article 5 requires a renewal application no later than 18 months before expiry. A timely application keeps the existing exemption valid until the Commission decides. A rejection or revocation decision must set expiry between 12 and 18 months after that decision. Check the exact Annex entry, category, application, renewal filing, and delegated decision.

Article 4(5) sets a separate route for reused spare parts recovered from qualifying older EEE. Reuse must occur in an auditable closed-loop business-to-business return system and be notified to the consumer. The part must be used in EEE placed on the market before the applicable cutoff. The 22 July 2024 cutoff for qualifying medical-device or monitoring-equipment parts and the 22 July 2026 cutoff for qualifying in vitro diagnostic parts have passed. The remaining dates are 22 July 2027 for qualifying industrial monitoring parts and 22 July 2029 for qualifying formerly out-of-scope EEE. Article 4(4) has separate rules for specified cables and spare parts used with older EEE, so the end of an Article 4(5) reused-part route does not answer every repair case.

Evidence timing depends on each release. Manufacturers retain technical documentation and the EU declaration of conformity for 10 years after placing the EEE on the market. EN IEC 63000:2018 was published as the harmonised RoHS technical-documentation standard in 2020, and the EN 50581:2012 reference was withdrawn on 18 November 2021. Harmonised standards are voluntary; assessment under a cited standard gives a presumption of conformity only for the requirements it covers.