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
- 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.
- 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).
- Test each homogeneous material: Perform XRF screening on each pigmented material layer, followed by ICP-OES for confirmation of any borderline results.
- For plasticized PVC: Verify phthalate content (DEHP, BBP, DBP, DIBP) if pigments are used in flexible PVC for EEE applications.
- 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.
- 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.