“Your side requires a RoHS 3 report” — this statement appears very often in emails buying and selling electronic components, but if you look up on the European legal information portal, you will not find any document named “RoHS 3”. This is an unofficial name set by the market, and that informality causes very costly misunderstandings: some businesses test exactly 10 substances but cite the wrong basis, some businesses think they only need to meet 6 substances.
This article decodes the actual RoHS text chain — from the original Directive to the applicable amendments — so that businesses know exactly what they are complying with, and know how to answer when customers ask about “RoHS 3”, “RoHS 2.0” or “RoHS 10 substances”.
1. Why is “RoHS 3” an unofficial designation?
In the EU legal system, documents are identified by number and year, not by “version 1, 2, 3” like software. A Directive can be modified by the Authorization Directive or Amendment Directive, but after amendment, the document still carries the old number (with the caption “amended”).
“RoHS 3” is therefore not a document name, is not a newly issued version, and has no legal effect of its own. This is an industry shorthand for expansion of the list of restricted substances — specifically the addition of the phthalate group to the list.
2. True RoHS text string
| Text | Role | Point to remember |
|---|---|---|
| Directive 2002/95/EC | First RoHS document | Initial list of 6 restricted substances; Applicable since mid-2006 for most electrical and electronic equipment |
| Directive 2011/65/EU | Recast, replacing text 2002/95/EC | Expanding product groups and exemption mechanisms according to Annex III/IV, associated with the obligation to affix CE marking and declaration of conformity |
| Authorization Directive (EU) 2017/2102 | Modify the definition and scope definition | Associated with expanding the scope of application to previous device groups beyond the list |
| Authorization Directive (EU) 2015/863 | Add 4 phthalates to the list of restricted substances | This is “RoHS 3” as the market calls it; The list of substances is limited to 10 substances |
| Directive (EU) 2025/2456 | Modifications to the technical review mechanism for waivers | Transferring exemption technical assessment activities to the European Chemicals Agency (ECHA); Signed at the end of November 2025, published in the EU Official Gazette on December 12, 2025 |
This table shows something important: Directive 2011/65/EU is still the original document that applies. Other documents are revised. Therefore, in the technical dossier and declaration of conformity, the correct basis is always “Directive 2011/65/EU, as amended” — with a list of amendments related to that product.
3. Phthalate supplementation: what really changes?
The revision known to the market as “RoHS 3” added four phthalates to the restricted substances list: DEHP, BBP, DBP and DIBP. This is a common group of plasticizers in soft PVC plastics — cable covers, gaskets, handles, insulating covers.
Three points businesses often ask:
- Applicable limit: These phthalates are subject to a limit of 0.1% by mass of homogeneous material, as are lead, mercury, hexavalent chromium, PBB and PBDE. Cadmium alone has a stricter limit.
- When to apply: Does not apply on the same day for all product groups. Common equipment, medical equipment and monitoring and control tools have their own landmarks; In vitro diagnostic equipment and industrial monitoring instruments have the latest milestones.
- Scope of application of materials: The limit is based on homogeneous materials, so a cable can be reached in the PVC sheath but exceeded in the inner adhesive layer. This is why the sample dissection step is more important than the testing equipment.
4. “RoHS 2”, “RoHS 6 substances”, “RoHS 10 substances” — what should we call it correctly?
| How to call in the market | In essence | How to write correctly in resume |
|---|---|---|
| RoHS 1 | Directive 2002/95/EC | Directive 2002/95/EC (expired, only has historical value and handles old inventory) |
| RoHS 2 | Directive 2011/65/EU, rewritten | Directive 2011/65/EU |
| RoHS 3 | Informal term, usually referring to phthalate supplementation | Directive 2011/65/EU as amended by Delegation Directive (EU) 2015/863 |
| RoHS 6 substances | List of restricted substances before the phthalate addition | It is necessary to clearly state: list of substances applied by time and product group |
| RoHS 10 substances | Current restricted substances list | Directive 2011/65/EU has been amended, including 10 restricted substances |
| RoHS 4 | Does not exist in current reality | No citation; Based on actual documents only |
For documents sent to European customers, the safest way is Avoid using the words “RoHS 3” and clearly write the legal basis. A line like “complies with Directive 2011/65/EU as amended, including Delegate Directive (EU) 2015/863” is both short enough and unlikely to be misinterpreted.
5. Why does this naming pose a real risk?
There are three specific risks when businesses use informal names in technical communication:
- Requires range trial error. The customer requests “test according to RoHS 3” — if the tester understands that only 4 phthalates need to be tested and ignores the remaining 6 substances, the report will not reflect the correct compliance requirements.
- Misquoted in declaration of conformity. A declaration of conformity stating “RoHS 3 compliant” has no legal value because it does not state the Directive and specific amendments.
- Misunderstanding the application roadmap. For the same product, the application limit of phthalates may be different depending on the product group; If the document only says “RoHS 3”, it is impossible to determine which mold the product belongs to.
6. Correct writing in contracts, quotes and technical documents
| Situation | Recommended writing style | Avoid |
|---|---|---|
| Request a test sent to the lab | Name the substance, limit, homogeneous material and applicable method standards | Says “RoHS 3 tested” without substance list |
| Declaration of conformity sent to customers | State “Directive 2011/65/EU, as amended” and list the applicable amendments | Write “meets RoHS 10 substances” as a legal basis |
| Terms of sales contract | Clearly state the obligation to comply with “RoHS according to EU regulations applicable at the time of delivery” | Hard-record a way to call the version, easily outdated when there are new modifications |
| Declare materials to customers | Include the effective date of the data and commit to notify when there are structural changes | List only the substance name without the update date |
7. For Vietnamese businesses, what does this chain mean?
Most Vietnamese businesses are not the party responsible for final compliance, but are the party that must provide evidence. Four things should be standardized:
- Finalize the list of 10 substances in every material declaration form, with limits for each substance.
- Record applicable milestones for phthalates according to customer product groups — especially for customers making medical devices and measuring instruments.
- Cite the text, not the nickname in all reports, statements and contracts.
- Track new edits — for example changes to the exemption review mechanism noted in the late 2025 document — to update records before customers ask.
8. Frequently asked questions
What should I do if a customer requests “RoHS 3 report”?
You should ask for a list of substances and specific limits. In practice, most require “RoHS 3” to mean “full 10 restricted substances”. The report should clearly state the list of substances tested and standard methods of application, with an answer explaining why there is no document named “RoHS 3”.
Is the old report stating “RoHS 2” still available?
There are two things to check: whether the report includes four phthalates, and whether the phthalate application milestone for your product group has been reached. If the report only has 6 substances and products in the group where phthalates were applied, the report is no longer sufficient.
Is there any document named “RoHS 4”?
There are currently no documents issued under that name. The latest changes come in the form of an amendment to Directive 2011/65/EU, not a “new version” that replaces it.
What if we only export to China, Japan or Korea?
Each market has its own substance restriction program with different substance lists and schedules. Test reports using international standard methods can often be used for many markets, but the legal citation and application date must be written for each market.
Why are revisions often associated with the July milestone?
Many RoHS milestones are tied to application by product group, not by date of issuance. Therefore, carefully reading the scope of application is more important than remembering the date of publication of the document.
9. Conclusion
“RoHS 3” is a convenient nickname but has no legal value. When working with European customers, what needs to be accurate is not the version name but the Document number, substance list, applicable limits and benchmarks.
Three things should be done immediately: standardize the form for citing legal bases in all documents; Review old reports to confirm the inclusion of phthalates according to the correct product group milestone; and keep track of new revisions so you’re not surprised when customers update their requirements.
References
- Directive 2011/65/EU on restriction of the use of certain hazardous substances in electrical and electronic equipment (consolidated version).
- Directive 2002/95/EC (original RoHS text, expired).
- Delegation Directive (EU) 2015/863 adds four phthalates to Annex II.
- Delegation Directive (EU) 2017/2102 amends the definition and scope of application.
- Directive (EU) 2025/2456 amending the technical assessment mechanism for exemptions (published in the EU Official Gazette December 2025).
Related articles
- Selling electronics on Amazon/eBay Europe: how must foreign sellers prove RoHS?
- What is RoHS? Complete guide to Directive 2011/65/EU and its 10 restricted substances
- Directive (EU) 2025/2456: RoHS moves technical assessment to ECHA — what businesses need to know
- RoHS Annex III exemption: three delegated directives 2025/2364, 2025/1802, 2025/2363 and deadlines 2026–2027
- 10 RoHS restricted substances: how do the 0.1% and 0.01% limits apply to “homogeneous materials”?
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Disclaimer
This article is an interpretive content compiled by us; not legal advice. Enterprises need to compare relevant documents/standards verbatim before applying them to specific products.
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