RoHS Compliance — Pigment Regulatory

EU Directive

RoHS Compliance — Restriction of Hazardous Substances for Pigments

Directive 2011/65/EU + amendments · 10 restricted substances for electrical and electronic equipment

Overview

RoHS (Restriction of Hazardous Substances), codified under Directive 2011/65/EU with subsequent amendments, restricts the use of specific hazardous substances in electrical and electronic equipment (EEE) sold in the European Union. The directive now covers 10 restricted substances — the original six plus four phthalates added under RoHS 3 (Directive 2015/863). For pigment formulators and users, RoHS directly governs which pigments can be used in plastics, coatings, cables, connectors, and housings for electronic products.

Scope

RoHS applies to:

  • All EEE placed on the EU market (11 categories from medical devices to consumer electronics)
  • Homogeneous materials — any material that cannot be mechanically disjointed into different materials
  • Maximum concentration values (MCV) apply at the homogeneous material level, not the finished product level
  • Compliance is demonstrated through technical documentation, not pre-market approval

RoHS applies at the homogeneous material level — meaning each individual material layer in a component (e.g., the plastic housing pigmented with a specific colorant) must meet the limits independently. This makes pigment selection critical: a single non-compliant pigment in even a minor component can render the entire product non-compliant.

RoHS Evolution: From 6 to 10 Substances

RoHS 1 (2002/95/EC): 6 substances (Pb, Cd, Hg, Cr6+, PBB, PBDE). RoHS 2 (2011/65/EU): CE marking requirement, expanded scope. RoHS 3 (2015/863): Added 4 phthalates — DEHP, BBP, DBP, DIBP — relevant when pigments are used in plasticized PVC compounds for EEE. Effective date for new EEE categories: 22 July 2019.

Restricted Substances & Pigment Implications

Substance RoHS Limit (ppm in homogeneous material) Affected Pigments Exemptions Status
Lead (Pb) <1000 ppm (0.1% w/w) PY34 (Lead Chromate Yellow), PR104 (Lead Molybdate Red), Lead Molybdate Orange Annex III exemptions for specific applications (e.g., certain glass/ceramics) RESTRICTED
Cadmium (Cd) <100 ppm (0.01% w/w) PO20 (Cd Sulfoselenide), PY35 (Cd Sulfide), PR108 (Cd Selenide) Very limited; none applicable for general pigments PROHIBITED
Mercury (Hg) <1000 ppm (0.1% w/w) PR106 (HgS / Vermilion), Mercury-Cadmium Red Fluorescent lamps (phased out); not applicable to pigments PROHIBITED
Hexavalent Chromium (Cr6+) <1000 ppm (0.1% w/w) Chrome oxide green (PG17) if Cr6+ contamination present; zinc chromate anti-corrosion pigments Annex III exemptions for anti-corrosion coatings (time-limited) RESTRICTED
PBB & PBDE (flame retardants) <1000 ppm (0.1% w/w) No direct pigment impact N/A for pigments NOT APPLICABLE
DEHP, BBP, DBP, DIBP (phthalates) <1000 ppm (0.1% w/w) each Indirect: pigments used in plasticized PVC may contribute if phthalates used as processing aids Only applicable to flexible PVC in EEE; not relevant for most pigment-loaded polymers GENERALLY COMPLIANT
Organic pigments (PR254, PB15:3, PG7, PV19, PY150) No heavy metals by design N/A — inherently compliant No exemptions needed COMPLIANT
Iron Oxides (PR101, PY42, PBk11) Trace metals must be verified N/A — typically compliant Verify Pb/Cd/Cr6+ by ICP-OES per batch COMPLIANT (IF VERIFIED)
Titanium Dioxide (PW6) No restricted metals N/A — inherently compliant No exemptions needed COMPLIANT
Carbon Black (PBk7) No restricted metals N/A — inherently compliant No exemptions needed COMPLIANT

⚠ Critical: Homogeneous Material Level Testing

RoHS limits apply at the homogeneous material level, not the total product. A pigmented plastic housing must have Pb <1000 ppm in the plastic itself — not averaged across the entire device. This means a 0.5% loading of a lead chromate pigment in a housing material could easily create a RoHS non-compliance. Market surveillance authorities routinely test individual materials using XRF screening followed by ICP-OES confirmation. Non-compliance results in withdrawal from the EU market and potential penalties across all 27 member states.

Affected Pigments & Compliant Alternatives

The most significant RoHS impact on pigment selection relates to lead, cadmium, and hexavalent chromium. The following substitution guide helps identify RoHS-compliant pigment choices for electronic and electrical applications:

Restricted Pigment CI Name RoHS Issue Compliant Alternative Alternative CI
Lead Chromate Yellow PY34 Pb >1000 ppm Bismuth Vanadate Yellow, Benzimidazolone Yellow PY184, PY151
Lead Molybdate Red / Orange PR104 Pb >1000 ppm, Cr6+ DPP Red, Benzimidazolone Orange PR254, PO72
Cadmium Yellow PY35 Cd >100 ppm Bismuth Vanadate, Isoindolinone Yellow PY184, PY110
Cadmium Orange / Red PO20 Cd >100 ppm DPP Orange, Perinone Orange PO73, PO43
Cadmium Red PR108 Cd >100 ppm DPP Red, Quinacridone Red PR254, PR122
Mercury Cadmium Red Hg >1000 ppm, Cd >100 ppm DPP Red, Perylene Red PR254, PR178
Chrome Oxide Green (contaminated) PG17 Cr6+ contamination Phthalocyanine Green, Cobalt-Free Green PG7

How to Comply

  1. Audit your pigment portfolio: Identify all pigments containing Pb, Cd, Hg, or Cr6+ in any form. Pay special attention to lead chromates and cadmium-based pigments — these are the most common RoHS non-compliance root causes in EEE.
  2. Substitute restricted pigments: Replace lead chromates (PY34, PR104), cadmium pigments (PY35, PO20, PR108), and mercury-based reds with modern organic alternatives (DPP, quinacridone, perylene, bismuth vanadate).
  3. Test each homogeneous material: Perform XRF screening on each pigmented material layer, followed by ICP-OES for confirmation of any borderline results.
  4. For plasticized PVC: Verify phthalate content (DEHP, BBP, DBP, DIBP) if pigments are used in flexible PVC for EEE applications.
  5. Verify purity of “safe” pigments: Even organic pigments and iron oxides may carry trace heavy metal impurities from their manufacturing process. Require CoA with full metals analysis from suppliers.
  6. Document compliance: Maintain a Technical File per EN 50581:2012 including material declarations, test reports, and supplier declarations of conformity.

Documentation Required

Document Purpose Standard
Certificate of Analysis (CoA) Heavy metal content (Pb, Cd, Hg, Cr6+) per batch ICP-OES per ISO 11885
XRF Screening Report Rapid screening of homogeneous materials IEC 62321-3-1
ICP-OES Confirmation Quantitative analysis of borderline samples IEC 62321-5 (Cd/Pb/Hg), IEC 62321-7-2 (Cr6+ in polymers)
Supplier Declaration of Conformity Written statement from pigment supplier confirming RoHS compliance EN 50581:2012
RoHS Technical File Complete compliance dossier for EEE product Directive 2011/65/EU, Annex II
Phthalate Analysis DEHP, BBP, DBP, DIBP content (plasticized PVC only) IEC 62321-8 (GC-MS)

RoHS-Compliant Pigments for Electronics

Our high-performance organic pigment portfolio is inherently RoHS-compliant. Full heavy metal analysis available with every shipment.

Request RoHS CoA