Restriction of Hazardous Substances (RoHS)

The Restriction of the Use of Certain Hazardous Substances (RoHS) in Electrical and Electronic Equipment Directive (2011/65/EU) aims to prevent certain hazardous substances being used in  the production of electrical goods thereby keeping them from entering the waste stream.


Manufacturers, authorised representatives, importers and distributors of electrical and electronic equipment within the scope of RoHS need to comply with the directive.

If you consider or have reason to believe that a product you are responsible for does not comply with the directive you must meet certain requirements which include:

  •         notifying market surveillance authorities
  •         informing the supply chain
  •         taking remedial action

The Notifications and Actions document which can be accessed below provides guidance on this aspect of the legislation and aims to explain Regulatory Delivery’s approach to these obligations and our expectations.


This table summarises the obligations of all economic operators that are affected by RoHS.

legal obligations


authorised representative




any supplier of an EEE for distribution, consumption or use in the course of a commercial activity and markets it under their own name

anyone with a written mandate from a manufacturer to carry out administrative tasks on their behalf when placing EEE on the market

anyone who imports EEE from outside the EU and places it on the EU market

anyone in the supply chain, other than the manufacturer or importer, who makes EEE available on the EU market

design and manufacture EEE in compliance with RoHS




place only compliant EEE on the EU market


draw up technical documentation






implement production control systems and checks to ensure compliance




draw up an EU Declaration of Conformity




affix CE mark




ensure the EEE is accompanied by required documents



ensure that technical documentation, in addition to the declaration of conformity, remains available for 10 years after the EEE is placed on the market


ensure that the EEE has been CE marked by the manufacturer



keep a register of all non-compliant and/or recalled EEE



ensure that the manufacturer keeps a register of all non-compliant and/or recalled EEE




ensure that the manufacturer has carried out an appropriate assessment of conformity




ensure that the manufacturer has drawn up technical documentation




ensure that the EEEremains compliant for as long as it is produced




ensure that the EEE is marked with type/serial/batch number for identification





ensure that the EEE is marked with the manufacturer’s trademark/trade name and address



ensure that the EEE is marked with the importer’s trade name and address




take corrective measures to ensure that any non-compliant EEEbecomes compliant


if requested, provide the NMRO with all the information required to demonstrate conformity

cooperate with the NMRO and take any action it requests to ensure conformity

meet all manufacturer obligations if you market EEE under your own trademark/trade name




The RoHS Directive 2011/65/EU is part of UK law under The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012.

It has since been amended by a number of delegated regulations which can be accessed via the RoHS section of the European Commission website.

Last Updated: 11/08/2017
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