Fact sheet: Electrical and electronic equipment (RoHS)

As of 1 July 2006, new electrical and electronic equipment must not contain the following harmful substances:

  • lead
  • mercury
  • cadmium
  • hexavalent chromium
  • polybrominated biphenyls (PBBs)
  • polybrominated diphenyl ethers (PBDEs)

The restrictions apply to small and large household appliances, IT and telephone equipment, consumer equipment (radios and TVs etc.), lighting equipment (including bulbs), electrical and electronic tools, toys, leisure and sports equipment and vending machines. Other types of equipment became part of the scope in the last recast of the directive (RoHS recast or RoHS 2). As of:

22 July 2014: medical devices as well as monitoring and control instruments;         

22 July 2016: in vitro diagnostic medical devices;

22 July 2017: industrial monitoring and control instruments;

22 July 2019: all the rest of electric and electronic equipment

must not contain the above mentioned harmful substances.

Reducing harmful substances is good for the environment and human health

The restrictions aim to protect consumers from dangerous substances, for instance brominated flame retardants can cause birth defects and cancer. In addition, the equipment will be less dangerous to the environment when it eventually becomes waste and may be easier to recycle.

Manufacturers, importers and distributors are responsible

The import or sale of products that do not comply with the regulation is prohibited within the EU. Enterprises must ensure that equipment does not contain the prohibited substances.

The Environmental Protection Agency’s chemical inspectors monitor compliance with the regulation and will ensure that illegal situations are brought into compliance. This may involve withdrawing the product from the Danish market, or making the product legal in some other way. Anyone who breaches the regulations may additionally face a fine or prison sentence of up to two years.

No specific documentation requirements

The Danish Environmental Protection Agency has not specified any documentation requirements enterprises must fulfil to demonstrate compliance with the regulation. It is up to individual enterprises to ensure that any suppliers they use supply components that comply with the RoHS regulations. Enterprises may choose to select suppliers with a well-documented quality assurance system that can serve as documentation. It may also be necessary to perform a technical analysis to document that equipment complies with the regulation.

Exemptions where no alternatives exist

The use of mercury in fluorescent tubes and lead in certain soldering materials is still permitted. All exemptions are listed in statutory order 1331 of 17 Novenber 2016. 

The European Commission can grant exemptions in cases where it is not technically possibly or environmentally advantageous to replace the dangerous substances with substitutes. Enterprises seeking such an exemption must send an application to the Commission, proving that it is not possible to use other substances. Valid exemptions are published in the Annex III in the EU and national regulations.

Does not apply to old equipment

Equipment transferred for the first time within the EU prior to 1 July 2006 does not have to fulfil the requirements. It can be freely resold after 1 July 2006. It is not a requirement that equipment has been sold to the consumer.

Equipment produced within the EU is considered to have been transferred once the finished equipment has been physically moved from the producer to a later stage in the distribution chain, or if a binding legal agreement has been made regarding transfer of ownership.

Products imported from non-EU countries are considered to have been transferred when they have cleared customs. It is a good idea to supply/request documentation in later stages of the distribution chain that shows the equipment was transferred from the producer before 1 July 2006. Such documentation may be necessary during later supervision and inspection.

The regulations also apply to spare parts

Components are covered if they are to be used as spare parts. Components to be used in equipment covered by the RoHS Directive must fulfil the requirements. Spare parts only to be used for old equipment (see above) are not covered.

More exemptions

Some electrical and electronic equipment are explicitly excluded from the scope, such as:

  • Military and space equipment
  • Large stationary industrial tools
  • Equipment that uses voltages above 1000 V (AC) or 1500 V (DC)

Special regulations apply to batteries. The RoHS Directive does not change these requirements.

The requirements do not apply to equipment exported from the EU, but other local requirements may apply in the recieving country.

More information

The full text of the regulations is available in Danish at the Retsinfo website:

  • Statutory Order 1331 of 17 November 2016 limiting the import and sale of electrical and electronic equipment containing certain dangerous substances.

The Danish statutory order is based on the EU directive available at EUR-Lex:

  • EU Directive 2011/65/EU (the RoHS Directive) on the restriction of the use of certain dangerous substances in electrical and electronic equipment.

The European Commission has websites on the WEEE and RoHS Directives. This site has links to historic versions of the directives, technical documents and news:

The WEEE Directive website

The RoHS Directive website