Global RoHS legislation: Key differences and compliance challenges

This article is provided by BRC Associate Member, UL Solutions.

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Restriction of Hazardous Substances (RoHS) legislation has become a cornerstone of chemical compliance for electrical and electronic equipment (EEE) worldwide. While the European Union (EU) RoHS Directive is often regarded as the global reference, countries and regions have adopted RoHS-type regulations with some differences in scope, substance coverage and conformity assessment. Understanding these variations is essential for manufacturers operating across multiple markets. What follows explores where RoHS requirements diverge and what this means for managing compliance across global supply chains.

EU RoHS as the global benchmark

The EU RoHS Directive (2011/65/EU) establishes a comprehensive framework. It applies to nearly all EEE under an “open scope” approach and restricts 10 substances, including heavy metals, flame retardants and four phthalates. Compliance is demonstrated through self-declaration supported by technical documentation (to be prepared according to EN IEC 63000:2018 standard) and test reports, typically aligned with IEC 62321 standards. Many other jurisdictions have chosen to align closely with this structure but rarely replicate it in full.

Variations in scope and product coverage

One of the most visible differences globally concerns the scope of regulated products. The EU, Turkey, Ukraine and the UAE apply RoHS broadly to almost all EEE, with China progressively expanding its RoHS scope to cover a wider range of EEE. In contrast, Japan and California adopt narrower, product-specific approaches. Japan’s RoHS-style controls apply primarily to selected household appliances and IT equipment, while California focuses largely on lighting products and electronic displays. These narrower scopes reduce regulatory burden but create fragmentation for global manufacturers.

Differences in restricted substances

Substance lists also vary. While many regions now restrict the same 10 substances as EU RoHS (including China, UAE, Turkey and Ukraine), others still regulate only the original six substances: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). Japan, South Korea and Saudi Arabia fall into this category. California is even more limited, restricting primarily heavy metals. These differences can complicate material declarations and supplier management, as products compliant in one region may require reformulation for another.

Conformity assessment and certification requirements

Another major divergence lies in conformity assessment. The EU, Turkey, Ukraine, Japan and South Korea rely largely on self-certification, placing responsibility on the manufacturer. China introduces additional complexity by distinguishing between products included in a regulatory catalog and those outside it. Catalog products may require third-party certification or formal self-declaration uploaded to a government platform. The UAE and Saudi Arabia go further by mandating third-party certification through government-approved schemes — Emirates Conformity Assessment Scheme (ECAS) in the UAE and SABER in Saudi Arabia — making these markets more administratively demanding.

Testing standards and documentation

Most jurisdictions accept test reports based on the IEC 62321 series, reinforcing international harmonization. China represents a partial exception, requiring testing to national GB/T methods for formal certification. Some regions, such as California, are more flexible and accept manufacturer-generated evidence.

Conclusion

In summary, global RoHS legislation shares a common objective — reducing hazardous substances in EEE — but differs in execution. Manufacturers face the greatest challenges from variations in product scope, substance lists and certification requirements rather than technical limits themselves. As more countries align with EU RoHS principles, convergence is improving, yet regional differences remain a critical consideration in global compliance strategies.

UL Solutions can help

For more details and to know more on how UL Solutions can support your business, please contact katie.ellen.moore@ul.com.