Four New RoHS Phthalates: Are You in Scope?

Four New RoHS Phthalates: Are You in Scope?

The European Union (EU) Restriction of Hazardous Substances (RoHS) Directive first came into effect in July 2006, with the aim of reducing the impact of potentially harmful substances in electrical and electronic equipment (EEE) on human and environmental health.

Later, in January 2013, the EU RoHS recast came into effect with an increased scope, expanded exemptions and the ability for regulators to add more substances as needed.

While the RoHS Directive had the greatest impact on electronics companies, the scope went well beyond. Electrical and electronic equipment is found in a variety of products in a wide range of verticals — any product that requires electrical currents or electromagnetic fields in order to function, and all parts associated with these products, are considered in scope.

This can include any product with a digital display, a power cord or batteries. As companies embrace technology and incorporate electronic parts into a broad range of consumer items, this brings an increasing number of products in scope of RoHS.

When RoHS came into effect, companies were subject to restrictions on six chemicals and their compounds at the homogeneous material level:

  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Hexavalent chromium (Cr6+)
  • Polybrominated biphenyls (PBB)
  • Polybrominated diphenyl ether (PBDE)

Are you in scope of EU RoHS? Download the EU RoHS Scoping Guide to find out.


This year, restrictions on four new phthalates will come into effect, which will heavily impact products containing cables, wires and power cords, as well as buttons on items such as car stereos and instrument panels. After July 22, 2019, the following four substances cannot be placed on the EU market in concentrations above 0.1 percent weight by weight (w/w), with the exception of monitor and control equipment and medical devices:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Benzyl butyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Companies will need to reevaluate whether these materials are present in products and make the necessary adaptations to maintain market access.

In order to make this determination, companies will need to survey the supply chain to obtain product material data. Any part that contains substances over threshold will need to be reformulated or replaced.

Many companies that sell, manufacture or distribute in-scope products have already begun supplier outreach to collect the necessary data on the presence of these phthalates. For those that have not yet begun, it’s recommended they start now so they have the time to make any part adjustments that may be needed to remain compliant.

Assent’s RoHS Module streamlines the supply chain outreach and data collection processes, enabling companies to maintain compliance with EU RoHS as the directive changes.

To learn more about how Assent’s supply chain data management platform can automate your RoHS program, contact info@assentcompliance.com.

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