Complying with New Substance Restrictions in the European Union RoHS2 Directive

Date: December 17, 2018

From July 22, 2019 onward, most all Electrical and Electronic Equipment (EEE) sold in the European Union, other than that which is explicitly excluded, must comply with new substance restrictions in the Restriction of Hazardous Substances (RoHS2) Directive (also see 2015 update). To show that you are in compliance with this directive, it is mandatory to use the CE (Conformité Européenne) marking for your electrical and electronic products.

About RoHS 2

An important aspect of EU RoHS2 Directive is that it enables the European Commission to add new substance restrictions, in addition to the existing heavy metals and brominated flame retardants that have been restricted since 2006. European Commission Delegated Directive 2015/863 was published 4 June 2015 and added the phthalates DEHP, BBP, DBP and DIBP with maximum concentration values of 0.1% in homogenous materials to the list of substances in Annex II of the RoHS Directive. These four new RoHS substance restrictions apply to electrical and electronic equipment from 22 July 2019, with an exemption for medical devices and monitoring and control instruments until 22 July 2021. Electrical and electronic equipment which contains more than 0.1% of these phthalates in any homogenous material is banned from the European market from 22 July 2019, with an exemption for medical devices and monitoring and control instruments until 22 July 2021.

The following are restricted chemicals

Current Restrictions

  • Cadmium(Cd): 0.01%
  • Mercury: 0.1%
  • Lead(Pb): 0.1%
  • Hexavalent chromium (Cr6+): 0.1%
  • Polybrominated biphenyls (PBB): 0.1 %;
  • Polybrominated diphenyl ethers (PBDE): 0.1 %

Additional Restrictions in 2019

  • Bis (2-Ethylhexyl) phthalate (DEHP): 0.1%
  • Benzyl butyl phthalate (BBP): 0.1%
  • Dibutyl phthalate (DBP): 0.1%
  • Disobutyl phthalate (DIBP): 0.1%

The additional four (DEHP, BBP, DBP and DIBP) are chemicals primarily used as plasticizers to soften plastics..

Many companies are really struggling to meet the RoHS requirements for their products. Managing Substance Compliance and Material Reporting over all the respective countries for all products is very time consuming and expensive. It is a real challenge to manage all materials and substances used in-house and to collect all declarations from your supply chain.

In 2016, the RoHS2 Administrative Co-operation Network (AdCo) coordinated several enforcement projects across Europe. In seven countries, 157 cables were tested and the result was alarming: 24% were not compliant with RoHS2 and 37% contained phthalates.

thinkstep provides three different approaches to ensure that your company, your products and your components are compliant with the latest directive.


If you need assistance in meeting the legal requirements of RoHS2, our experts can advise you on how to implement a substance compliance process in your company.

Supporting Tool

To support managing large amounts of substance data in different formats and systems, our substance compliance tool will enable you to have clear structures, processes and responsibilities according to best practices.

Automation of supplier communication throughout your supply chain is the second advantage of our substance compliance tool, which allows you to automate with very little effort, improving the entire process.

The tool also makes substance compliance data easily available for your in-house reporting and for reporting to your customers. You will be able to effortlessly generate industry-standard or customer-specific reports.

Full Service

If you don´t want to have internal resources dedicated to substance compliance and material reporting, you can use our full-service approach. We can collect and manage all data needed for you to fulfill all legal requirements. In this case, we get in touch with your supply chain and ensure that you receive the declarations from your suppliers. We deliver documentation and reports for all your in-house and procured products to guide your decisions regarding substance compliance.

To find out how we can assist you, please contact:

Daniel Schott
thinkstep AG
Phone +49 711 341 817 269
Mobile +49 151 61310234


>> More information about Product Compliance

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