RoHS (RoHS)

RoHS (Restriction of Hazardous Substances) is the European Union directive (2011/65/EU, recast from 2002/95/EC) that prohibits the placing on the market of electrical and electronic equipment containing six original hazardous substances above defined concentration limits — lead (1,000 mg/kg), mercury (1,000 mg/kg), cadmium (100 mg/kg), hexavalent chromium (1,000 mg/kg), polybrominated biphenyls (PBB, 1,000 mg/kg), and polybrominated diphenyl ethers (PBDE, 1,000 mg/kg). The 2015 amendment (RoHS 3) added four phthalate plasticisers (DEHP, DBP, BBP, DIBP at 1,000 mg/kg each), bringing the total to ten restricted substances applicable from 2019 onward.

RoHS is enforced at point of import into the EU through product technical files, supplier declarations of conformity, and CE marking requirements. Non-compliant products trigger withdrawal from market, fines, and brand damage. While RoHS itself is EU law, it has become a global de facto standard because no major electronics manufacturer maintains separate non-compliant product lines for non-EU markets. Indian electronics manufacturers — Dixon, Wistron, Foxconn India, and domestic brands like Lava and Micromax — uniformly produce RoHS-compliant products for both domestic and export markets, making the directive operationally relevant inside India even though no Indian law mirrors it directly.

For Indian e-waste recyclers, RoHS context matters in two ways. First, newer e-waste (post-2010) contains substantially less lead solder (replaced by tin-silver-copper alloys), no cadmium pigments or batteries, no hexavalent chromium coatings, and fewer BFRs — making downstream processing safer and more profitable. Second, recyclers serving EU brands as part of their EPR programmes must demonstrate that recovered material streams (recycled plastic resin, metal alloys) remain RoHS-compliant when re-entering the supply chain, requiring XRF verification and chain-of-custody documentation. Indian Battery Waste Management Rules 2022 and the broader EPR framework do not formally adopt RoHS, but customer-driven compliance — particularly for electronics destined for Tata, Samsung, Apple, and other RoHS-aligned brand supply chains — pulls Indian recyclers and component suppliers into RoHS-equivalent practice. The directive remains the global benchmark for what constitutes acceptable substance content in new and recycled electronics.

• EU directive 2011/65/EU restricting 10 hazardous substances in electrical and electronic equipment.
• Original six: Pb, Hg, Cd, Cr(VI), PBB, PBDE at 100–1,000 mg/kg limits; four phthalates added 2015.
• Global de facto standard via supply chain integration; no Indian law mirrors it directly.
• Post-2010 e-waste is far cleaner due to RoHS compliance — easier and safer for recyclers.