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RoHS 3 & REACH - How Electronics Buyers Can Stay Compliant

Substances named in RoHS 3 are prohibited in electronics sold into the EU, and similar standards apply in the US.

If you’ve ever looked at a component datasheet or a container of solder paste, you’ve probably noticed language or markings pertaining to RoHS 3 and REACH compliance. As part of the heavy metal removal movement in heavy industry, the Restriction of Hazardous Substances (RoHS) Directive applies to products manufactured and taken to market in the EU. The RoHS directive was originally introduced in 2002 and is currently updated to Revision 3, which was introduced in 2015.

While the United States and Canada do not have direct equivalents to RoHS 3, designing and manufacturing to RoHS 3 compliance is generally sufficient to comply with environmental regulations on electronics in these countries. There is also the more broad-reaching REACH directive to consider, which spans beyond electronic components/assemblies to include all materials used to manufacture a product. Substances named in these regulations might be used in your electronic components, and it pays to know how to verify compliance when buying parts.

RoHS and REACH Requirements

Any company that plans to develop an electronic product for sale in the EU has a responsibility to ensure compliance with RoHS and REACH. This task is handled in different ways by multiple parties. For instance, semiconductor manufacturers, materials suppliers, electronics assemblers, and other component manufacturers must ensure compliance with these directives for the products they sell or use in the fabrication/assembly process.

RoHS 3 is the newest revision of the RoHS directive, with implementation being required as of 2019. The RoHS lists specific hazardous substances whose concentration must be limited in electrical and electronic equipment. Manufacturers are also responsible for proving compliance; this involves documentation such as independent certification, conformity declarations from vendors, internal testing results, or 3rd party testing results.

The list of hazardous substances listed in RoHS 3 and their maximum acceptable concentrations are found in the table below. The phthalates listed below were newly added to the RoHS 3 directive

  • Lead (Pb): 7439-97-6 (CAS Number), 1000 ppm max concentration
  • Mercury (Hg): 7439-92-1 (CAS Number), 1000 ppm max concentration
  • Cadmium (Cd): 7440-43-9 (CAS Number), 100 ppm max concentration
  • Hexavalent Chromium (Cr(VI)): 18540-29-9 (CAS Number), 1000 ppm ppm max concentration
  • Polybrominated biphenyls (PBBs): 1000 ppm max concentration
  • Polybrominated diethyl ethers (PBDEs): 1000 ppm ppm max concentration
  • Bis(2-ethylhexyl) phthalate (DEHP): 1000 ppm ppm max concentration
  • Butyl benzyl phthalate (BBP): 1000 ppm ppm max concentration
  • Dibutyl phthalate (DBP): 1000 ppm ppm max concentration
  • Diisobutyl phthalate (DIBP): 1000 ppm max concentration

The other compliance element that applies to electronic components is also the REACH directive. This directive intends to limit hazardous substances that may appear at the product level or at the component level. It applies to all parts of an electronic assembly or end product, including the enclosure, mechanical elements, packaging materials, plastics, and specialty compounds required in the assembly. REACH is also an EU directive without a direct equivalent in the US and Canada, however compliance with REACH is a starting place for ensuring compliance with North American hazardous substances regulations.

RoHS 3 and REACH Compliance for Components

Any of the named substances above could be used in the manufacture of electronic components, so any RoHS 3/REACH compliant product should only include materials and components that are compliant with these directives. Semiconductor manufacturers, OSATs, EMS companies, and assemblers play different roles in ensuring compliance with these directives. As a customer of an EMS company, contract manufacturer, or assembly house, your first job is to ensure their compliance with directives if your end product requires it.

Given the potential use of RoHS 3 named substances in electronic components and packaging, buyers should also verify whether their components are affected by REACH and RoHS 3 directives. If your EMS provider is handling sourcing, you can take advantage of their supply chain management systems and processes. Manufacturers often engage in rigorous supply chain management, including obtaining compliance statements from their material suppliers, conducting internal testing or third-party testing, and maintaining proper documentation to ensure traceability and compliance.

If you’re buying components for a captive operation or consignment to an assembler, you can also request RoHS and REACH compliance information from suppliers or component manufacturers. You can also look for components that explicitly state their compliance status through certifications or declarations, which are sometimes found in datasheets. This helps ensure that the components used in their products meet the necessary regulatory requirements and align with environmental and safety standards.

When you’re looking for some parts, you’ll sometimes see a lead-free variation on the part number, which is a good sign the part will be RoHS and REACH compliant. For example, Analog Devices names their legacy Linear Technologies part numbers with a “#PBF” suffix to specifically indicate RoHS compliance.

RoHS/REACH Compliance in Supply Chain Tools

If you use an ERP platform or an online supply chain visibility service, you can often get access to compliance information directly while searching component data. Platforms like Cofactr give you total visibility into the supply chain, including data on RoHS and REACH compliance status as specified by manufacturers.

Cofactr gives electronic component buyers instant visibility into component information and RoHS 3 compliance for their electronic parts. Electronic design teams and procurement professionals use Cofactr to quote, purchase, manage inventory, and manage logistics for their electronic components. Cofactr also provides warehousing and logistics management services through its online platform.

Zachariah Peterson


Owner, NWES | PCB Design for RF, Mil-Aero, Data Center, AI/ML

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