RoHS-like regulations first appeared in the EU and have since been implemented worldwide. Although these regulations differ and are based on different processes, their aims are broadly similar. This article summarizes RoHS regulations in countries beyond the EU, namely China, Japan, Russia, Turkey, and South Korea.
The EU RoHS Directive gave rise to a large number of initiatives on RoHS substances in electrical and electronic equipment around the world. To date, because of the significance of this topic, RoHS-like regulations have been implemented in dozens of different jurisdictions outside Europe. As electronic products increasingly move through international supply chains, understanding these overlapping requirements has become important for any manufacturer selling beyond a single market. This article looks at how several major markets, namely China, Japan, Russia, Turkey, and South Korea, have adopted their own RoHS-style requirements. It highlights where those requirements align with the EU model and where they differ, since even small variations in scope, restricted substances, or conformity procedures can carry practical consequences for compliance.
Most of the major world markets are, or will be, aligned with the EU in promulgating RoHS-like regulations. China, Japan, Russia, Turkey, South Korea, Singapore, India, the UAE, Norway, and others have laws in effect that are similar to EU RoHS. In the USA, several states, including Colorado, Indiana, Minnesota, Illinois, New York, Rhode Island, and Wisconsin, have RoHS-like laws, as does California.
Although EU RoHS has been adopted by many countries in its original form, this is not always the case. Countries may introduce a completely different approach with regard to:
China RoHS took effect on 1 March 2007. Concentration limits for the restricted substances are published in Requirements of Concentration Limits for Certain Restricted Substances in Electrical and Electronic Products (GB/T 26572-2011). The Chinese Ministry of Industry and Information Technology (MIIT) is responsible for maintaining the database of products subject to RoHS restrictions, and it also publishes the list of product categories subject to compliance, as well as the list of exemptions. All electronic and electrical products sold in China must be marked with the proper symbol.
Table 1. China RoHS compliance symbols
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Japan RoHS combines the Japanese Recycling Law (Law for Promotion of Effective Utilization of Resources in Japan) with the JIS C 0950 standard (Marking for the Presence of Specific Chemical Substances for Electrical and Electronic Equipment), and is known as J-MOSS. All items that belong to one of the RoHS product categories should be marked with either an orange "R" mark or a green "G" mark, depending on whether any of the six restricted substances exceed the concentration limits.
Table 2. Japan RoHS (J-MOSS) compliance symbols, green "G" and orange "R"
Russia RoHS came into force on 1 March 2018. The Eurasian Economic Union (EAEU), comprising Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia, has enacted the Technical Regulation TR 037/2016 (On the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products). In addition to restricted substances and concentration limits, the regulation provides a list of product categories that fall within the scope, as well as a list of exemptions. TR 037/2016 is one of the technical regulations required for EAC marking (the Eurasian Conformity mark). EAC-marked products meet all requirements of the corresponding technical regulations, and products without the EAC mark cannot be placed on the market.
Turkey RoHS was enacted in June 2009 (having been announced in the Official Gazette on 30 May 2008, No. 26891). The Turkish Ministry of Environment and Forestry harmonized both the Restriction of Hazardous Substances (RoHS) and the Waste Electrical and Electronic Equipment (WEEE) Directives with national legislation, as announced in the Official Gazette on 22 May 2012 (No. 28300). Although Turkey RoHS is very similar to the EU Directives, it does retain some differences; for example, only six hazardous substances (lead, mercury, hexavalent chromium, cadmium, PBBs, and PBDEs) fall within the scope of the law.
South Korea RoHS went into effect on 1 January 2008. South Korea promulgated the Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles on 2 April 2007, which shares similarities with the EU RoHS, WEEE, and ELV Directives. A 2020 amendment to Korea RoHS added four phthalates, which means that it currently covers all ten EU RoHS substances.
Figure 1. Comparison of restricted substances across major RoHS jurisdictions
RoHS laws continue to expand globally, so compliance is fundamental to global market access. While the regulations covered here share the same underlying aim of reducing hazardous substances in electrical and electronic equipment, the differences in scope, restricted substances, marking requirements, and conformity procedures mean that compliance in one market does not automatically guarantee compliance in another. For this reason, companies with a global footprint tend to design worldwide RoHS-compliant products, aiming to meet the strictest applicable requirements so that a single product can be sold across multiple markets. As more countries continue to introduce and tighten their own RoHS-style regulations, staying informed of these evolving requirements will remain an ongoing part of doing business internationally.
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