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New RoHS Directive Amendment and Category 11 Product Type

On Monday, 22 July 2019, EU Directive 2015/863 added 4 new restricted substances as well as product Category 11 to the original list of 6 substances and original 10 categories laid out in Directive 2002/95/EC and amended by Annex II of Directive 2011/65/EU.

What does that really mean for manufacturers and importers?

The new directive is applicable to all new electrical and electronic products placed on the European Union market – regardless of being imported or manufactured in the EU, and it requires that products bearing the ‘CE’ mark are presumed to comply with the directive (in the absence of evidence to the contrary).

Any EEE products not covered by the original Categories 1-10 come into scope as Category 11 products (i.e., 2-wheeled electric vehicles, electronic cigarettes, cannabis vaporizers, vape pens, electrical cables less than 250V, etc.) and have slight differences when compared to the other categories:

  • All products, regardless of their import date, must comply after 22 July 2019 (stock from before 22 July 2019 may no longer be sold in the EU unless already compliant).
  • No allowances are made for non-compliant spare parts after 22 July 2019.

What are the 10 restricted substances?

The original 6 substances consisted of 4 heavy metals and 2 flame retardants:

  • Lead (Pb) – a heavy metal used in printed circuit boards, paints, and pigments.
  • Mercury (Hg) – a heavy metal used in lighting and automotive switches.
  • Cadmium (Cd) – a heavy metal used in plastic pigmentation and photocells.
  • Hexavalent Chromium (CR VI) – a heavy metal used to prevent corrosion of metal finishes.
  • Polybrominated biphenyls (PBBs) – flame retardant used in appliances, electronics, and textiles.
  • Polybrominated diphenyl ethers (PBDEs) – flame retardant used in electronics and furniture.

All the new additions are phthalates – a plasticizing compound used to add flexibility and durability:

  • Bis(2-Ethylhexyl) phthalate (DEHP) – used in cable insulation and as a softener for PVC.
  • Butyl benzyl phthalate (BBP) – used in flexible adhesives, coatings, inks, and vinyl products.
  • Dibutyl phthalate (DBP) – used in flexible varnishes, nail polish, and variety of rubbers and paints.
  • Diisobutyl phthalate (DIBP) – used in printing inks, adhesives, and cosmetic applications.



What are the effective dates?

Effective Date


22 July 2019

1: Large Household Appliances (LHA)

22 July 2019

2: Small Household Appliances (SHA)

22 July 2019

3: IT and Telecoms Equipment

22 July 2019

4: Consumer Equipment

22 July 2019

5: Lighting Equipment

22 July 2019

6: Electrical and Electronic Tools

22 July 2019

7: Toys, Leisure and Sports Equipment

22 July 2021

8: Medical Devices

22 July 2021

9: Monitoring and Control Equipment (including Industrial)

22 July 2019

10: Automatic Dispensers

22 July 2019

11: Other EEE not covered above (catch-all)


Are there exemptions or transition periods?

Category 8 and 9 products have 2 years remaining and fall into scope on 22 July 2021. There are additional exemptions for specific applications or industries; the current status is reported on the European Commission website.

How can Total Parts Plus help?

TPP provides customers with dedicated resources for the time-consuming tasks of surveying suppliers, out of scope assessments, conducting analytical research, validating data, and monitoring exemptions.

TPP customers also have access to our extensive database of pre-approved compliant parts via our web-based Compliance Management Module (CMM) which empowers companies to easily manage and monitor their environmental compliance data.

How do you get started?

Contact Total Parts Plus to learn more or schedule a demo.
Call:       +1.850.244.7293