RoHSTimeline

EU RoHS Directive (2011/65/EU) Timeline

The dates you must know - and what changed.

Use this timeline to set cutovers, plan supplier re-verification, and avoid exemption expiry surprises.

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Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

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Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

RoHS has multiple timelines running at once: (1) the legal evolution from RoHS 1 to the RoHS 2 recast, (2) staged applicability dates by EEE category, (3) substance list updates, especially the phthalates, and (4) exemptions that expire and must be renewed on time. This page collects the key dates and explains what to do at each inflection point.

Section 1

2002 - 2013: RoHS 1 to RoHS 2 (recast) and national implementation

RoHS began as Directive 2002/95/EC (RoHS 1). Directive 2011/65/EU (RoHS 2) recast the regime, updated scope, and set the modern exemptions process.

Operational impact: by the time RoHS 2 took effect via national law, companies needed repeatable evidence packs, not one-time declarations.

By 2 January 2013: Member States adopt and publish transposition measures
3 January 2013: RoHS 1 repealed; RoHS 2 framework becomes the baseline
2013 onward: technical documentation, DoC, and CE marking expectations become the practical enforcement surface

Section 2

2014 and 2017: staged category applicability expands (medical and monitoring)

RoHS staged some categories into scope. Treat the staged dates as hard ship gates for those categories: you must have a defensible RoHS position for products first placed on the EU market after the relevant date.

Use these dates to plan supplier re-verification, targeted testing, and technical file readiness ahead of time.

22 July 2014: medical devices enter RoHS scope via staged applicability
22 July 2016: in vitro diagnostic medical devices enter RoHS scope
22 July 2017: industrial monitoring and control instruments enter RoHS scope
Practical action: pre-stage evidence packs for high-risk plastics, cables, coatings, and components

Section 3

2019: open scope and the big classification shift

RoHS moved to open scope for remaining EEE in Category 11 and staged additional products into scope from 22 July 2019. This is where many companies first discover that their non-EEE assumption was wrong.

Operational action: run an applicability sweep across product lines, classify into Annex I categories, and create a defensible exclusions record where applicable.

22 July 2019: open scope and remaining EEE staged into scope
Supplier impact: update contract clauses and evidence requirements (declarations + change notification)
Evidence impact: homogeneous material mapping becomes essential at portfolio scale

Section 4

2019 and 2021: RoHS 3 phthalates restrictions (two cutovers)

Delegated Directive (EU) 2015/863 added four phthalates (DEHP, BBP, DBP, DIBP) to the restricted substances list (Annex II) with staged applicability dates. This is often the highest-risk RoHS change for plastics and cables.

Action: schedule supplier re-declarations and targeted testing ahead of each cutover, then enforce it as a release gate.

22 July 2019: phthalates restrictions apply for most EEE
22 July 2021: phthalates restrictions apply for medical devices + monitoring/control instruments
Carve-outs exist for certain cables/spare parts used to repair/reuse/update older equipment (placed on the market before the cutover dates)

Section 5

Ongoing: exemptions renewals and annex updates never stop

Annex III/IV exemptions are time-limited and require proactive renewal dossiers. RoHS sets a strict renewal deadline (>=18 months before expiry) and defines what happens if a renewal is rejected (phase-out window).

Treat exemptions as expiring risk: if an exemption disappears, your redesign path and supplier qualification plan must already exist.

Renewal submitted >=18 months before expiry; exemption remains valid until decision
Current Commission guidance says decisions typically take 18 to 24 months from application
If renewal rejected/revoked: expect 12 - 18 months to phase out (plan redesign capacity)
Track exemptions operationally (expiry alerts, product mapping, and evidence packs)

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