EU Regulatory Regime · Medium
RoHS — Restriction of Hazardous Substances in EEE — importer obligations + worked example
Status
Status: Active since 2011 (recast 2011/65/EU).
What you must do as the importer
Verify EEE complies with restriction limits on Pb, Cd, Hg, Cr(VI), PBB, PBDE, and four phthalates (DEHP, BBP, DBP, DIBP). DoC must reference RoHS. Technical file retained 10 years. Non-compliance = market withdrawal + fines.
What goods are covered
- 85 — Electrical and electronic equipment
- 8413 — Pumps for liquids
- 8418 — Refrigerators / freezers
- 8421 — Centrifuges, filters
- 8422 — Dishwashing machines
- 8450 — Washing machines
- 8451 — Dryers
- 8470 — Calculating machines
Worked example: a typical shipment that triggers
A €50,000 shipment of electronics (HS 850000) from CN into the EU triggers RoHS — Restriction of Hazardous Substances in EEE. The customs duty + VAT are calculated as normal — but on top of that, the importer must satisfy the obligations above before the goods can be placed on the EU market.
Non-compliance is not a duty event — it is a market-access event
A common misunderstanding: importers focus on duty + VAT and treat compliance as a tickbox. EU customs increasingly hold goods at the border for missing documentation (DDS for EUDR, CBAM declarant status for steel/aluminium, EU Responsible Person for cosmetics). Holds become storage charges; storage charges become forced re-export. Validate before booking the freight.
Related OrcaTrade resources
See whether this regime applies to your specific shipment
Six questions, all four calculators (sourcing, routing, customs, warehouse), full landed cost — with this regime flagged on your specific HS code if applicable.
Build my plan with this regime checked →