ROHS Circuit Board: Eco-Friendly Solutions for Electronics



ROHS-compliant circuit Board is becoming increasingly important in the electronics industry. ROHS, which stands for Restriction of Hazardous Substances, regulates the use of certain hazardous materials in the production of electronic devices and components. By restricting materials like lead, cadmium, mercury, and chromium VI, ROHS aims to reduce the environmental and health impacts of electronic waste.

RoHS Circuit Board
RoHS Circuit Board


For printed circuit board (PCB) manufacturers, meeting ROHS requirements involves careful material selection, process changes, and quality control. However, the benefits are reduced toxicity, improved recyclability, and an environmentally sustainable production model. With electronics playing an ever greater role across society, ROHS principles help the industry account for its impacts.

This guide will provide a comprehensive overview of the ROHS circuit Board, covering:

Overview of ROHS Regulations

The ROHS Directive originated in the European Union (EU) and has gone through several iterations since its initial adoption in 2003. ROHS 1 refers to the original Directive 2002/95/EC which took effect in 2006. This focused on restricting six hazardous substances in electrical and electronic equipment (EEE) sold in the EU market.

The current expanded version is known as ROHS 2 or the ROHS Recast under Directive 2011/65/EU. ROHS 2 updated the scope to cover additional product categories while keeping the same six substance restrictions. It also added four phthalate plasticizers to the list of banned substances.

Over time, ROHS has aimed to gradually expand its scope and increase the stringency of substance limits to further reduce the presence of hazardous materials in electronics. This is driven by concerns about the environmental and health impacts of electronic waste.

The directives impose concentration limits on 10 substances:

  • Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium, Polybrominated Biphenyls (PBB), Polybrominated Diphenyl Ethers (PBDE) [Original 6 substances]
  • Bis(2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP), Di isobutyl phthalate (DIBP) [Phthalates added under ROHS 2]

The maximum threshold is 0.1% (1000 ppm) of the homogeneous material weight which will progressively reduce further. Homogeneous material means a uniform composition substance that can be separated mechanically.

ROHS 2 also greatly expanded the scope of applicable product categories covering all major types of electrical and electronic equipment (EEE). This includes household appliances, IT equipment, consumer electronics, industrial instruments, luminaires, power tools, toys, automatic dispensers, and medical devices.

The legislation does allow for certain application-specific exemptions from substance limits, which are reviewed periodically. As reliable substitutes are developed, exemptions have their expiration timelines reduced. The aim is to continuously motivate innovation and adoption of green alternatives.

ROHS Requirements for PCBs

Since PCBs are core components of electrical equipment, meeting ROHS poses significant implications for PCB material selection, fabrication, assembly, and testing processes.

Key requirements include:

  • Base materials like FR-4 composites must avoid brominated flame retardants (BFRs) exceeding ROHS limits
  • Prepregs used for PCB multilayer bonding must be BFR-free
  • Lead-free solders such as Sn-Ag-Cu alloys must replace tin-lead solders
  • Surface finishes cannot use hexavalent chromium or cadmium plating
  • Alternatives like ENIG, immersion silver, OSP, and immersion tin should be used
  • Components must have lead-free terminations and solders
  • Clear ROHS labels and markings required on PCBs
  • Certificate of Conformity declaring ROHS compliance
  • Test reports to validate substance concentrations in materials

With careful selection of materials and process controls, PCB assemblers can achieve full compliance. However, this requires coordination across the entire supply chain.


Achieving ROHS Compliance

For PCBs headed into EU markets, comprehensive documentation is essential to demonstrate ROHS conformance. This includes:

  • Material Declarations: Suppliers must provide substance information
  • Certificates of Conformity: Declaring ROHS compliance
  • Testing Reports: Validating substance levels through analytical tests
  • Product Markings: Clear ROHS labels on PCBs and finished goods
  • Supply Chain Traceability: Documentation covering the full production process

Third-party certification standards like IPC-1752 and UL 1007 also help streamline compliance verification for EU customers.

Maintaining rigorous traceability and testing provides auditable proof that ROHS requirements are met from raw materials to final PCBs.

Cost Impact and Future Outlook

Adapting to ROHS compliance did initially increase costs for electronics manufacturers as new materials, processes, and documentation systems were needed. However, over time these costs have stabilized as the supply chain matured.

Looking ahead, the scope and stringency of ROHS is expected to expand further worldwide:

  • More product categories likely to be covered
  • Potential for tighter substance concentration limits
  • Additional substances could face restriction
  • Phase out of exemptions as substitutes emerge

This will require manufacturers to continually monitor regulatory changes and adjust their processes and material sourcing accordingly. However, the long-term benefits for health and the environment will make ROHS principles indispensable for responsible electronics production.


Overview of ROHS Regulations

Brief History of RoHS Adoption

The ROHS Directive originated in the European Union (EU) as “Directive 2002/95/EC” which was adopted in February 2003 and took effect in July 2006. This original version focused on restricting six key hazardous substances in electrical and electronic equipment (EEE) sold in the EU market.

The current expanded version is referred to as “ROHS 2” or “ROHS Recast” under Directive 2011/65/EU. This updated the legislation to cover additional electronic products while keeping nearly the same substance restrictions.

Some key events in the ROHS regulatory timeline include:

  • Feb 2003 – Original ROHS Directive enters force
  • Jul 2006 – ROHS 1 mandatory for EEE in the EU market
  • Jan 2011 – ROHS 2 Directive published
  • Jan 2012 – ROHS 2 enters into force
  • Jan 2013 – ROHS 2 compliance required

Over time, the scope has expanded and maximum concentration limits have become more stringent. ROHS principles are now established worldwide with similar regulations in places like China, Japan, and the USA.

Substances Restricted Under ROHS

The original list of six substances restricted under ROHS are:

Restricted Substances
Restricted Substances


  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Hexavalent Chromium (Cr6+)
  • Polybrominated Biphenyls (PBB)
  • Polybrominated Diphenyl Ethers (PBDE)

Additionally, ROHS 2 added restrictions on the following phthalate plasticizers:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Di isobutyl phthalate (DIBP)

The maximum concentration limit is 0.1% (1000 ppm) of the homogeneous material weight for each substance. Homogeneous material means uniform composition substances that can be separated mechanically.

Product Categories Under ROHS

ROHS 2 broadly covers electrical and electronic equipment (EEE) that:

  • Uses electric currents or electromagnetic fields for functioning
  • Generates, transfers, or measures such currents and fields
  • Falls under 1000V AC or 1500V DC voltage limits

Within this scope, applicable product categories include:

  • Household appliances like refrigerators, washing machines
  • IT equipment like laptops, printers, routers
  • Consumer electronics like mobile phones, TVs, game consoles
  • Industrial monitoring and control instruments
  • Luminaires and household lighting
  • Power tools, toys, sports gear with electrical parts
  • Automatic dispensers
  • Medical devices

Categories currently excluded are aerospace equipment, military products, large industrial tools, implantable medical devices, and more. But the scope has been expanding.

Exemptions Under ROHS

For certain applications where eliminating hazardous substances is technically impractical, the ROHS Directive allows exemptions from the concentration limits.

Some current exemptions include:

  • Lead in high melting temperature type solders
  • Lead in server and storage system batteries
  • Lead in glass or ceramics
  • Mercury in fluorescent lighting applications

However, exemptions have expiration timelines to push innovation. As reliable substitutes emerge, exemptions phase out to uphold ROHS principles through continuous improvement.

ROHS Requirements for PCBs

Since PCBs are core components of nearly all electrical and electronic equipment, meeting ROHS compliance poses significant implications for materials, processes, and quality control during PCB fabrication and assembly.

As PCBs fall squarely within the scope of ROHS-regulated products, manufacturers must overhaul their material sourcing, handling, fabrication methods, assembly processes, testing, and documentation practices to adhere to the stringent hazardous substance restrictions.

While adapting to these changes does entail costs, the long-term benefits of reduced toxicity, improved recyclability and environmentally sustainable electronics manufacturing compels PCB producers to fully integrate ROHS disciplines into their operations.

Some key requirements across the PCB production process include:

Substrate and Laminate Materials

  • Base laminate materials like standard FR-4 composites, which use brominated flame retardants (BFRs), must be replaced with high Tg, low loss laminates that avoid brominated and chlorinated compounds exceeding ROHS concentration limits
  • Specialty laminates using high glass transition temperature materials with phosphorus-based FR additives aid thermal performance during lead-free assembly while meeting RoHS norms
  • Prepreg bonding films for multi-layer PCB construction cannot contain BFRs and must also adhere to ROHS materials compliance
  • Composite substrates derived from ceramics or using reinforced woven glass or metal core layers require careful vetting to restrict regulated phthalate plasticizers


  • Lead-based solders can no longer be used for component termination finishes or PCB assembly due to high lead content. Lead-free solders such as the tin-silver-copper (SAC) alloy family must replace conventional tin-lead solders.
  • Solder flux formulations also require reformulation to eliminate restricted substances and enable high-temperature lead-free soldering


  • Plating processes can no longer use hexavalent chromium compounds due to carcinogenic hazards posed during the plating process as well as reliability risks from chromium residues
  • Cadmium plating is also prohibited due to its regulated status as a carcinogen and toxic heavy metal with extensive risks even at low concentrations
  • Surface finish alternatives such as electroless nickel immersion gold (ENIG), immersion silver, organic solderability preservatives (OSP), and immersion tin should be used to provide solderability while meeting RoHS norms


  • Parts must utilize lead-free terminations with pure tin, nickel-palladium-gold, or other Pb-free surface plating to enable soldering with ROHS-compliant solders
  • Component materials for cases, connectors, and other parts must also adhere to the restricted substance limits to enable fully ROHS-compliant assembly
  • Lead frames in packaging as well as solder used for die attach require a shift to RoHS-compliant alternatives

Marking and Documentation

  • Unambiguous RoHS labeling and markings are required on bare PCBs as well as assembled PCBs to ensure products contain compliant materials only
  • Certificate of Conformity with declarations of meeting ROHS standards for the specific PCB must accompany shipments
  • Comprehensive test reports need to validate that restricted substance concentrations in all materials are below the maximum permitted limits

With rigorous material evaluations, process changes, and quality control measures, PCB manufacturers can achieve fully ROHS-compliant production. However, this requires coordination between procurement, suppliers, assembly partners, and testing agencies along the supply chain.

Achieving ROHS Compliance

RoHS Compliant
RoHS Compliant


For PCBs destined for the EU market, comprehensive documentation and traceability are essential to demonstrate compliance with ROHS hazardous substance restrictions. Manufacturers must implement robust systems to provide auditable proof that the full supply chain and production processes uphold substance limits.

Material Declarations

  • Suppliers of base materials like laminates and prepregs, specialty substrates, solder, plating, coatings, and paste must provide detailed material declaration forms
  • These declaration forms must list all homogeneous materials and their constituent chemical compositions including any ROHS-regulated substances
  • The concentrations of the 10 restricted substances must be reported if present along with supporting analytical test data
  • IPC-1752 standard provides a framework for suppliers to furnish compliant material declarations

Certificates of Conformity

  • PCB manufacturers must issue a product-level Certificate of Conformity for each batch of Board shipped
  • This certificate declares that the PCBs meet ROHS standards and are compliant with EU market access
  • Details like PCB part number, revision, quantity, date of manufacture, and signature by the quality manager provide traceability

Testing Reports

  • Test reports from analysis of incoming raw materials at accredited laboratories must be maintained
  • This validates the restricted substance concentrations in laminates, prepregs, plating, coatings, etc. are within permissible limits
  • Common test methods include ICP-MS, GDMS, GC-MS, and LC-MS to quantify trace levels of regulated compounds

Product Markings

  • A clear indication of ROHS compliance through labeling is needed on bare PCBs and packaged end products
  • “Lead-Free” and “ROHS Compliant” markings on the board and packages leaving the PCB factory provide affirmation

Supply Chain Traceability

  • Lot-level traceability of raw materials from vendors through incoming inspection, inventory, PCB fabrication, assembly, inspection, testing, and shipment must be maintained
  • Comprehensive documentation across the sequence is essential to prove ROHS conformity at each process stage
  • Digitization of material and product data enables easier supply chain traceability

By implementing robust systems and procedures for material traceability, certificate issuance, product marking, and supply chain documentation, PCB companies can readily prove their ROHS compliance. Independent audits and certification also build trust.

Maintaining accurate substance records and traceable documentation at each process step is crucial to demonstrate due diligence in ROHS conformance for PCBs headed into EU markets.


ROHS Compliance Standards

To reduce the compliance burden, standardized ROHS certification allows PCB manufacturers to prove conformance more easily to customers.

IPC-1752 Materials Declaration Standard

  • Published by IPC to certify materials as ROHS compliant after extensive evaluation
  • Permits materials suppliers to provide verification certificates
  • Also covers components, PCBs, and electronic assemblies

UL 1007 Standard

  • ROHS verification standard from Underwriters Laboratories (UL)
  • Certifies materials meeting substance tests and requirements
  • Recognized proof of compliance for EU markets

These streamline compliance demonstration through independent validated certification.


Cost Impact of ROHS

Transitioning to ROHS compliance did increase costs for PCB manufacturers initially:

  • New substrate materials development
  • Lead-free solders and plating
  • Process and handling changes
  • Increased documentation overhead
  • Component level changes

However, over time the costs have stabilized as the supply chain matured. With scale benefits and standardized processes, ROHS is now well-integrated into electronics manufacturing with marginal impacts on pricing.


Future Outlook on ROHS

As environmental expectations grow globally, ROHS principles will continue expanding:

Finish Product for RoHS
Finish Product for RoHS


  • More stringent control limits expected
  • Additional substance restrictions likely
  • More product categories covered
  • Exemptions phased out with substitutes
  • Global convergence between regulations

This pushes manufacturers towards greater supply chain transparency, material innovation, and lifecycle design.



ROHS has fundamentally transformed materials and processes in PCB fabrication and assembly over the past two decades. Although adapting to compliance did entail initial costs, manufacturers have largely embedded ROHS disciplines into operations now.

With proper material selection, process controls, testing, and certification, PCB companies can readily achieve ROHS conformance for EU markets. As environmental expectations grow worldwide, ROHS principles will guide electronics supply chains to further reduce hazardous substance use.


Frequently Asked Questions (FAQs)

What is the maximum lead content allowed in ROHS-compliant PCBs?

For homogenous materials in a PCB, the maximum permissible lead content is 0.1% or 1000 ppm by weight. This threshold applies to any intentionally added lead or trace contaminants.

Can normal FR-4 laminates still be used for ROHS-compliant Boards?

Yes, FR-4 laminates are commonly used for ROHS PCBs. However, the FR-4 material must meet ROHS requirements by avoiding brominated flame retardants and using polymeric FR additives instead. ROHS-compatible FR-4 laminate grades are widely available.

Does ROHS compliance also need lead-free component soldering?

For full compliance, ROHS principles require lead-free soldering. So components must have lead-free terminations and Pb-free solders like SAC alloys must be used to solder parts to the PCB assembly.

How is ROHS enforcement done for non-compliant products?

Within the EU, enforcement is done through market surveillance. Customs and regulatory authorities can do sample testing to check for compliance, and force recalls or penalties if violations are found.

Can any deviations be allowed from the maximum substance concentrations?

Generally, no deviations are permitted from the maximum 0.1% concentration limit. However, in the IPC-1752 standard up to 0.2% is allowed for cadmium and mercury to account for trace amounts.

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