Procurement Glossary
RoHS: Definition, compliance requirements and implementation in Procurement
November 19, 2025
The RoHS Directive (Restriction of Hazardous Substances) is a central EU regulation that restricts the use of hazardous substances in electrical and electronic equipment. For purchasers, this means specific compliance obligations when selecting suppliers and procuring products. Find out below what RoHS covers, what implementation obligations exist and how you can successfully manage risks.
Key Facts
- RoHS restricts ten hazardous substances such as lead, mercury and cadmium in electrical appliances
- Applies to all electrical and electronic equipment placed on the EU market since 2006
- Manufacturers must provide CE marking and declaration of conformity
- Violations can lead to sales bans and fines of up to 100,000 euros
- Buyers share responsibility for the compliance of the products they procure
Contents
What is RoHS? Definition, purpose and scope of application
The RoHS Directive regulates the use of hazardous substances in electrical and electronic products throughout Europe.
Core elements of the RoHS Directive
RoHS stands for "Restriction of Hazardous Substances" and currently restricts ten groups of substances in electrical appliances. The most important regulated substances include
- Heavy metals: lead, mercury, cadmium and hexavalent chromium
- Flame retardants: polybrominated biphenyls (PBB) and diphenyl ethers (PBDE)
- Plasticizers: bis-2-ethylhexyl phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP)
RoHS vs. REACH Regulation
While REACH regulates the registration and evaluation of chemicals, RoHS focuses specifically on electrical appliances. Both sets of regulations complement each other in the context of compliance in Procurement and require coordinated implementation strategies.
Importance of RoHS in Procurement
For procurement managers, RoHS means specific duties of care in supplier evaluation and product qualification. Compliance is a prerequisite for EU market access and directly influences the supplier strategy in electronics procurement.
Implementation, obligations and evidence
Practical RoHS implementation requires systematic processes for supplier qualification and continuous monitoring of material composition.
Supplier qualification and documentation
Purchasers must request complete RoHS declarations of conformity from suppliers. These include material analyses, test reports from accredited laboratories and detailed substance lists of all components. A structured Supplier Code of Conduct should explicitly define RoHS requirements.
Test procedures and test methods
The substance concentrations are measured using X-ray fluorescence spectroscopy (XRF) or atomic absorption spectroscopy. The limit values are 0.1% by weight for most substances and 0.01% for cadmium. Random checks by independent testing institutes guarantee the reliability of supplier information.
Integration into procurement processes
RoHS compliance should already be defined as a knock-out criterion in the tendering phase. Contractual clauses must contain liability regulations in the event of violations and regular obligations to provide evidence. Due diligence also includes the evaluation of supplier sub-suppliers.
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Compliance key figures and quotas
Systematic key figures enable the monitoring and continuous improvement of RoHS compliance in procurement.
Supplier compliance rate
The quota of RoHS-compliant suppliers should be at least 98%. The percentage of suppliers with complete and up-to-date RoHS documentation in relation to the total number of active electronics suppliers is measured. Monthly evaluations identify potential for improvement and critical suppliers at an early stage.
Exam coverage and test rate
At least 15% of all electronics deliveries should be checked by independent RoHS tests. Sample selection is risk-based, taking into account supplier history, product complexity and country of origin. Deviation rates above 2% require immediate corrective action.
Response time in the event of violations
The average time from the identification of a RoHS violation to the implementation of corrective actions should be a maximum of 5 working days. This includes supplier communication, blocking of goods and initiation of corrective actions. Quick reactions minimize legal risks and business interruptions.
Risks, dependencies and countermeasures
RoHS violations can have considerable legal and economic consequences, which must be minimized through systematic risk management.
Legal and financial risks
RoHS violations can result in sales bans, product recalls and fines of up to 100,000 euros. In addition, there are costs for rework, storage of non-compliant goods and possible claims for damages. Liability also extends to importers and dealers, not just manufacturers.
Supply chain risks and dependencies
Complex supply chains make it difficult to ensure complete transparency regarding all materials used. There is an increased risk of incomplete or incorrect documentation, particularly for components from Asia. A robust ESG risk rating should take RoHS compliance into account as a key assessment factor.
Preventive countermeasures
Regular supplier audits, independent material tests and contractual guarantees significantly reduce compliance risks. The implementation of a Restricted Substances List creates clear guidelines for all parties involved. In addition, alternative suppliers should be qualified in order to reduce dependencies.
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Practical example
An automotive supplier implements a digital RoHS management system for its electronics procurement. All 450 suppliers must store their material compositions in a central database and update them regularly. The system automatically compares the information with the internal Restricted Substances List and flags critical components. During the incoming goods inspection, 20% of all deliveries are tested using X-ray fluorescence analysis. Within 18 months, the complaint rate was reduced from 8% to less than 1%, while inspection costs fell by 30%.
- Digital capture of all supplier documents
- Automated comparisons with prohibited lists
- Risk-based random checks
Current developments and interpretation of RoHS
The RoHS Directive is constantly evolving and is shaped by new scientific findings and technological advances.
Extension of the scope of application
Since 2019, medical devices and monitoring instruments have also been covered by RoHS. The EU Commission regularly reviews other product categories and substance groups for possible inclusion. Purchasers must proactively monitor these developments and adapt their supplier base accordingly.
Digitalization of compliance monitoring
Today, AI-supported systems enable automated monitoring of supplier documents and material compositions. Blockchain technology improves the traceability of materials along the entire supply chain. These tools significantly reduce the manual checking effort and increase compliance security.
Tightening up enforcement
Market surveillance authorities intensify their control activities and impose sanctions more frequently in the event of infringements. Cooperation between national authorities is strengthened by digital platforms. Companies should expand their internal control systems accordingly and carry out regular compliance audits.
Conclusion
RoHS is a key compliance component for all companies that procure or sell electrical and electronic equipment. Systematic integration into procurement processes, from supplier qualification to incoming goods inspection, minimizes legal risks and secures market access. Digital tools and AI-supported monitoring systems are increasingly becoming indispensable aids for efficient RoHS compliance.
FAQ
What does RoHS actually mean for buyers?
Purchasers must ensure that all electrical and electronic equipment procured complies with the RoHS limits. This includes the qualification of suppliers, obtaining declarations of conformity and regular spot checks. Importers and distributors can also be held liable in the event of non-compliance.
Which products are covered by the RoHS Directive?
RoHS applies to all electrical and electronic equipment placed on the market in the EU. This includes computers, household appliances, lighting, medical equipment and monitoring instruments. Exceptions only exist for special applications such as military equipment or large industrial plants.
How are RoHS limit values measured and verified?
The substance concentrations are measured in homogeneous materials, not in the overall product. The limit values are 0.1% by weight for most substances and 0.01% for cadmium. Detection is carried out by accredited testing laboratories using X-ray fluorescence or atomic absorption spectroscopy.
What happens in the event of RoHS violations?
Violations can lead to sales bans, product recalls and fines of up to 100,000 euros. In addition, costs are incurred for rectifications and possible claims for damages. Market surveillance authorities carry out regular checks and impose stricter sanctions in the event of repeated infringements.
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