Restricts the content of lead, mercury, cadmium, hexavalent chromium and four phthalates in electrical and electronic equipment. Self-declaration without a notified body — the manufacturer assesses conformity independently.
The RoHS Technical Regulation applies to electrical and electronic equipment (EEE) placed on the Ukrainian market. It covers 11 product categories.
Full list of categories: 1 — large household appliances; 2 — small household appliances; 3 — IT and telecommunications; 4 — consumer equipment; 5 — lighting equipment; 6 — electrical and electronic tools; 7 — toys, leisure and sports; 8 — medical devices; 9 — monitoring and control instruments; 10 — automatic dispensers; 11 — other EEE.
Concentration is measured as a percentage by weight of homogeneous material in any component of the product.
Maximum 0.1% by weight of homogeneous material
Maximum 0.1% by weight of homogeneous material
Maximum 0.01% by weight of homogeneous material
Maximum 0.1% by weight of homogeneous material
Maximum 0.1% by weight of homogeneous material
Maximum 0.1% by weight of homogeneous material
Bis(2-ethylhexyl) phthalate — max. 0.1%
Benzyl butyl phthalate — max. 0.1%
Dibutyl phthalate and diisobutyl phthalate — each max. 0.1%
The four phthalates (DEHP, BBP, DBP, DIBP) were added by Directive (EU) 2015/863. Categories 8 and 9 (medical devices and monitoring instruments) may have separate application dates.
The following categories of equipment are excluded from the RoHS Technical Regulation:
Some equipment may receive temporary exemptions where substitution of a particular material is technically or scientifically impracticable, or where the reliability of substitutes is unsatisfactory. The list of exemptions is in Annex III–IV of the directive.
The RoHS Technical Regulation provides for self-declaration: the manufacturer independently assesses conformity without involving a notified body.
The manufacturer prepares technical documentation demonstrating that substance concentrations comply with the limit values. This is based on material declarations from component suppliers and chemical analysis results.
No notified bodyThe manufacturer draws up a declaration of conformity referencing the RoHS Technical Regulation (CMU №139). If the product also falls under LVD, EMC or RED — a single combined declaration can be prepared.
Self-declarationThe conformity marking is affixed to the product or its packaging or documentation. Technical documentation and the declaration must be retained for at least 10 years.
No notified bodyDetermine scope of application
Check whether the product falls under one of the 11 EEE categories and whether any exclusion applies. Determine the application date for phthalate requirements for your category.
Collect material declarations from suppliers
Obtain material composition declarations from component suppliers (Material Declaration / Full Material Disclosure). For critical components — request XRF analysis or chemical testing results.
Technical documentation
Compile the technical file: product description, list of components and materials, supplier material declarations, test reports (if available), exemption analysis (if applicable).
Declaration of conformity
Draw up a declaration of conformity referencing the RoHS Technical Regulation (CMU №139). Where possible, combine with declarations for LVD, EMC or RED in a single document.
Marking and documentation retention
Affix the conformity marking. Retain the declaration and technical documentation for at least 10 years from the date the product is placed on the market. Provide documentation to supervisory authorities upon request.
The RoHS Technical Regulation applies in parallel with other technical regulations — declarations can be combined in a single document.
Applies to most EEE powered from the mains or with voltage exceeding 50 V AC / 75 V DC. RoHS and LVD declarations are frequently combined in a single document.
Learn more →Applies to the same EEE with respect to electromagnetic compatibility. RoHS and EMC declarations can be combined in a single document.
Learn more →Applies to radio equipment (Wi-Fi, Bluetooth, GPS, etc.). RED includes LVD and EMC requirements, but RoHS applies separately — declarations can be combined.
Learn more →All electrical and electronic equipment (EEE) in categories 1–11 placed on the Ukrainian market. This includes household appliances, IT, consumer electronics, lighting, power tools, toys, medical devices and other electrically powered devices.
No. The RoHS Technical Regulation provides for self-declaration: the manufacturer independently assesses conformity and draws up a declaration without involving a notified body.
For lead (Pb) — 0.1% by weight of homogeneous material. For cadmium (Cd) — 0.01% (ten times lower). For all other regulated substances — 0.1%.
A material of uniform composition throughout that cannot be mechanically disjointed into different materials. For example, solder on a PCB is a separate homogeneous material. Concentration is measured within that material, not across the entire product.
Yes. If a product falls under several technical regulations, a single declaration of conformity covering all applicable regulations (RoHS, LVD, EMC, RED) can be prepared. This is convenient and avoids duplication of documents.
Spare parts for the repair of EEE placed on the market before the requirements took effect may be exempt. New spare parts for new equipment are subject to the RoHS Technical Regulation.