This guide covers: EU RoHS — restricted substances, limits, and what a compliant certificate must state (POINT 01); REACH — the SVHC obligation, how it flows through the supply chain, and why a static certificate is not sufficient (POINT 02); halogen-free — the IEC 61249-2-21 standard, cost and electrical property implications, and how to specify it correctly (POINT 03); regional regulations across China, the US, and other markets (POINT 04); the full documentation set to require from any PCB manufacturer, and the operational practices that maintain compliance as regulations change (POINT 05).
The EU Restriction of Hazardous Substances Directive (2011/65/EU, commonly called RoHS 2) restricts the use of specific hazardous substances in electrical and electronic equipment placed on the EU market. Non-compliance means the product cannot legally be sold in the EU — and the liability falls on the entity placing the product on the market, not on the PCB manufacturer supplying into that product.
The 10 Restricted Substances — Current List
| Substance | Abbreviation | Max Limit | PCB Relevance |
|---|
| Lead | Pb | 0.1% | HASL surface finish (lead-free HASL required); solder paste in assembly |
| Mercury | Hg | 0.1% | Low direct relevance to bare PCBs; relevant to lamps in backlights |
| Cadmium | Cd | 0.01% | Historically used in some pigments; verify silkscreen ink formulation |
| Hexavalent Chromium | Cr(VI) | 0.1% | Used in some metal surface treatments; confirm surface finish chemistry |
| PBB | PBB | 0.1% | Brominated flame retardant; relevant to laminate material chemistry |
| PBDE | PBDE | 0.1% | Brominated flame retardant; relevant to laminate material chemistry |
| DEHP 2019 | DEHP | 0.1% | Phthalate plasticiser; may appear in flexible materials or coatings |
| BBP 2019 | BBP | 0.1% | Phthalate plasticiser; confirm with flexible and rigid-flex manufacturers |
| DBP 2019 | DBP | 0.1% | Phthalate plasticiser; low relevance for standard rigid PCBs |
| DIBP 2019 | DIBP | 0.1% | Phthalate plasticiser; low relevance for standard rigid PCBs |
The four phthalates (DEHP, BBP, DBP, DIBP) were added by Delegated Directive (EU) 2015/863 and apply to electrical and electronic equipment placed on the EU market from 22 July 2019 onward. If your RoHS certificates predate 2019 and have not been reissued, they cover only six substances — they are incomplete for current compliance.
What a Compliant RoHS Certificate Must State
DIRECTIVE REFERENCE
Directive 2011/65/EU — All 10 Substances
The certificate must reference Directive 2011/65/EU explicitly (not an earlier version), and must cover all 10 restricted substances — including the four phthalates added by Delegated Directive (EU) 2015/863. A certificate covering only the original six substances is not current.
SCOPE
All Materials in the Board
The compliance declaration must cover all materials incorporated into the finished PCB: base laminate, copper foil, solder mask, surface finish chemistry, silkscreen ink, and any via fill or specialty material. A certificate that specifies only the laminate or only the surface finish is not comprehensive.
ANALYSIS BASIS
Measurement Data or Verified Material Declarations
The strongest certificates are backed by third-party analytical results (XRF screening confirmed by ICP-MS or wet chemical analysis where needed). Self-declarations based on material data sheets from the laminate supplier are acceptable but carry more risk — the manufacturer is relying on their upstream supplier's compliance, which should also be verified.
VALIDITY
Tied to Current Material Formulation
A certificate is only valid for the materials actually used at the time of production. A laminate lot change, a solder mask reformulation, or a surface finish chemistry update requires re-issuance. Require the manufacturer to notify you of any material change that triggers a compliance re-evaluation — and to re-issue the certificate promptly.
RoHS exemptions for PCBs: The RoHS Directive includes Annex III and Annex IV exemptions for specific applications where compliant substitutes are not technically feasible. The most relevant for PCBs are exemptions covering lead in certain high-reliability solder joints, lead in certain glass or ceramic components, and lead in specific surface finishes for server and telecom applications. Medical device and military/aerospace applications have additional exemption categories. Confirm with your regulatory team whether any exemption applies to your specific application before specifying lead-free processes — and ensure the exemption number and expiry date are referenced in your compliance documentation.
The EU REACH Regulation (EC No 1907/2006) covers a far broader range of chemical substances than RoHS and operates through a different mechanism. Rather than prohibiting specific substances at defined thresholds, REACH creates disclosure and authorisation obligations that apply to substances of very high concern (SVHCs) throughout the supply chain — including in finished articles such as PCBs.
WHAT IS SVHC
Substances of Very High Concern
SVHCs are substances identified as carcinogenic, mutagenic, or toxic to reproduction (CMR category 1A or 1B); persistent, bioaccumulative, and toxic (PBT); very persistent and very bioaccumulative (vPvB); or substances of equivalent concern. The ECHA candidate list contained over 240 SVHCs as of 2024. It is updated twice annually — in June and December.
THE THRESHOLD
0.1% by Weight Per Article
The communication obligation is triggered when an SVHC is present above 0.1% by weight in any individual article — including a PCB as a standalone article. The 0.1% threshold is calculated per article, not per product. If a PCB contains an SVHC above 0.1%, the supplier must communicate this fact and the identity of the substance to the recipient.
SUPPLY CHAIN FLOW
Obligation Runs Through the Chain
The PCB manufacturer must receive SVHC declarations from their laminate, solder mask, and surface finish material suppliers. They must then aggregate this information and pass it downstream to their customers. This information flow must reach the end consumer of the finished product on request within 45 days — the obligation is not limited to B2B transactions.
WHY STATIC FAILS
SVHC List Updates Invalidate Old Declarations
An SVHC declaration issued in January may be incomplete by December of the same year — two new additions to the candidate list will have occurred in the interim. A declaration that was accurate when issued may not cover substances added after that date. This is why SVHC declarations must be tied to a specific list version date and updated at least annually.
⚠ Practical implication for procurement: When you request an SVHC declaration from a PCB manufacturer, specify: "SVHC declaration per ECHA candidate list as of [current month and year]." Do not accept a declaration with no list version date — it cannot be verified. Establish a process to request updated declarations at least annually, and to trigger re-request whenever the manufacturer notifies you of a material change. If the manufacturer cannot produce a dated SVHC declaration referencing the current candidate list, treat this as a supply chain compliance gap that requires resolution before the product enters the EU market.
Halogen-free is not a legal regulatory requirement in most jurisdictions — it is an industry environmental standard that is increasingly specified by product manufacturers as part of their environmental policy or eco-label compliance. Understanding what halogen-free means technically, what it costs, and how to specify it unambiguously is essential to procuring the correct product without surprises.
The IEC 61249-2-21 Definition
The standard definition for halogen-free PCB base materials is IEC 61249-2-21. A laminate qualifies as halogen-free under this standard when all three conditions are met simultaneously:
🟢Bromine content: below 900 ppm by weight
Bromine is the halogen introduced by conventional brominated epoxy resin flame retardants (tetrabromobisphenol A, TBBPA). Standard FR-4 typically contains 18,000–21,000 ppm bromine. Halogen-free FR-4 replaces brominated flame retardants with phosphorus-based systems, reducing bromine content to well below the 900 ppm limit.
🟢Chlorine content: below 900 ppm by weight
Chlorine can enter the laminate system from resin chemistry or processing solvents. Most halogen-free laminates from reputable suppliers achieve chlorine levels well below 900 ppm, but this must be confirmed by test data — not assumed from the absence of brominated flame retardants.
🟢Total bromine + chlorine: below 1,500 ppm
Even if both individual limits are met, the combined total must not exceed 1,500 ppm. A laminate with 850 ppm bromine and 850 ppm chlorine would individually pass each limit but fail the combined threshold. Request test data confirming all three conditions — not just the individual substance measurements.
Cost and Electrical Property Implications
COST
Typically 10–30% Premium Over Standard FR-4
Phosphorus-based flame retardant systems are more expensive than brominated alternatives, and the laminate manufacturing process for halogen-free materials is more tightly controlled. A 10–30% premium on laminate cost is typical, which translates to a smaller percentage increase in total board cost depending on layer count and complexity.
ELECTRICAL
Slightly Different Dk and Df Values
Halogen-free laminates use different resin chemistry, which results in slightly different dielectric constant (Dk) and dissipation factor (Df) values compared to brominated FR-4 of the same nominal grade. For low-frequency designs this is rarely significant. For high-frequency or RF applications, impedance-controlled designs should be re-simulated using the actual Dk/Df values of the specified halogen-free laminate before finalising the stackup.
THERMAL
Generally Higher Tg in Halogen-Free Grades
Many halogen-free FR-4 formulations have higher Tg ratings than the standard Tg 130–140°C material they replace — often Tg 150–170°C. This is a beneficial property for lead-free assembly compatibility. Confirm the Tg of the specific halogen-free laminate specified and verify it is appropriate for your reflow profile.
AVAILABILITY
Confirm with Manufacturer Before Specifying
Not all PCB manufacturers stock all halogen-free laminate grades. For less common thicknesses, copper weights, or high-layer-count builds, halogen-free material availability may extend the lead time or require a material pre-order. Confirm availability at your target lead time before committing the requirement in a firm purchase order.
How to specify halogen-free correctly: Do not write "halogen-free" without a standard reference — the term alone is not unambiguous. Write: "Halogen-free laminate per IEC 61249-2-21: Br ≤ 900 ppm, Cl ≤ 900 ppm, Br + Cl ≤ 1,500 ppm. Halogen-free certificate referencing IEC 61249-2-21 required with each shipment." Also confirm that the solder mask and surface finish are compatible with halogen-free compliance requirements — the laminate alone is not the only source of halogen content in a finished PCB.
EU RoHS and REACH are the most widely recognised frameworks, but products sold in other markets face their own regulatory requirements. The regulations below are the ones most commonly encountered in electronics procurement for markets outside the EU.
China RoHS
Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (2016)
Restricts the same six original RoHS substances (lead, mercury, cadmium, hexavalent chromium, PBB, PBDE) at equivalent thresholds. The primary additional requirement for products sold in China is a mandatory environmental information label on the product itself, and the publication of an environmental use period (EUP) — the period during which the product can be used without expected environmental risk from restricted substances. Manufacturers selling finished products in China must also comply with catalogue-based requirements for certain product categories.
Confirm whether your product category requires catalogue filing or only the standard labelling obligation.
California Prop 65
Safe Drinking Water and Toxic Enforcement Act of 1986
Requires businesses to provide clear warnings before knowingly exposing Californians to chemicals on the Prop 65 list — which includes lead at any detectable level. Any product containing lead-bearing solder, lead-containing surface finish, or lead from any other source — even by RoHS exemption — may require a Proposition 65 warning label if sold in California. The threshold for warning obligation is not a fixed percentage — it is based on the NSRL (No Significant Risk Level) for carcinogens and MADL for reproductive toxicants, which are very low for lead. Confirm your lead-free status across the entire PCB and assembly before concluding no warning is required.
Legal review is strongly recommended before concluding no warning obligation applies to a California-sold product.
Korea K-REACH
Act on Registration and Evaluation of Chemicals (Korea)
Korea's chemical substance framework parallels EU REACH in structure, requiring registration of chemical substances and disclosure of hazardous substance content in articles sold in Korea. Importers of electrical and electronic products into Korea must comply with K-REACH reporting obligations for substances on the Korean SVHC equivalent list. The specific substances and thresholds differ from EU REACH — do not assume EU compliance automatically satisfies K-REACH requirements.
Verify with a Korea-qualified regulatory advisor for product-specific obligations.
Taiwan TCSCA / Japan Kashinhou
Other Regional Chemical Regulations
Taiwan's Toxic Chemical Substances Control Act (TCSCA) and Japan's Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture (Kashin-hou / Chemical Substances Control Law) impose substance-specific notification and reporting obligations that may apply to PCB-related chemicals. For products sold in these markets at scale, a regional regulatory review is recommended — the compliance requirements vary by substance and product category and cannot be generalised from EU or US frameworks.
Consult a local regulatory specialist for market-specific obligations.
⚠ Regulatory landscape continues to evolve: The substances subject to restriction under all of these frameworks are subject to ongoing review and expansion. New SVHCs are added to the ECHA candidate list twice yearly; RoHS restricted substances can be expanded by delegated act; regional frameworks add substances on their own review cycles. Treating environmental compliance as a one-time activity at product launch — rather than a continuous monitoring function — is the most common source of undetected compliance gaps.
Environmental compliance is as much a documentation discipline as a materials discipline. The documentation below represents the minimum set that should be on file for every PCB supplier. The operational practices that follow are what maintain compliance currency as regulations change and materials evolve.
Documentation to Require from Every PCB Manufacturer
✓
RoHS Compliance Certificate — Directive 2011/65/EU, All 10 Substances
Must reference Directive 2011/65/EU (not earlier versions), must cover all 10 restricted substances including the four phthalates, must specify the scope of materials covered (laminate, solder mask, surface finish, silkscreen), and must include the issue date and the name of the authorised signatory. Re-issued whenever the manufacturer changes any covered material.
✓
REACH SVHC Declaration — Dated to Current ECHA Candidate List
Must reference the ECHA SVHC candidate list version date (not just "current list" without a date). Must cover all materials used in the PCB. Must be updated at least annually — and immediately upon any material change or SVHC list update that adds a substance present in the board. A declaration without a list version date cannot be evaluated for currency.
✓
Halogen-Free Certificate per IEC 61249-2-21 (if required)
Must reference IEC 61249-2-21 explicitly. Must state measured Br, Cl, and combined Br + Cl values — not just "conforms to IEC 61249-2-21." Certificate should be accompanied by supporting test data from an accredited laboratory. Re-issued whenever the laminate material source or formulation changes.
✓
Safety Data Sheets (SDS) — All Process Chemicals
SDS documents for all chemical substances used in the manufacturing process: laminate materials, solder mask, surface finish chemistry (including ENIG gold bath composition), silkscreen ink, and any specialty materials. Relevant both for your own chemical substance management obligations and as supporting evidence for compliance declarations.
✓
Third-Party Analytical Report (for critical or high-volume products)
An analytical report from an accredited laboratory (SGS, TÜV Rheinland, Bureau Veritas, Intertek) based on XRF screening or wet chemical analysis of actual board samples. Third-party analytical evidence provides independent verification that withstands regulatory scrutiny in a way that manufacturer self-declarations alone may not. Commission on a periodic basis — at least annually for critical products.
✓
ISO 14001 Environmental Management System Certificate
Confirms that the manufacturer has a certified environmental management system in place. Not a direct compliance document for RoHS or REACH, but evidence of systematic environmental management that supports the credibility of self-declarations. Verify certificate validity and scope with the issuing registrar — not from the manufacturer's copy alone.
Operational Practices That Maintain Compliance Over Time
📄Specify compliance requirements explicitly in every purchase order
State the applicable regulation, version, and substance list version by name in the procurement specification and purchase order. Do not use generic language such as "environmentally compliant" or "RoHS compliant" without specifying the directive version and substance scope. The specification commitment must be traceable to the specific regulatory version in effect at the time of supply.
🔄Require annual document refresh — and immediate notification of material changes
Build a document expiry review into your procurement calendar. Set a reminder 30 days before each certificate's annual renewal is due. In addition, require the manufacturer to notify you immediately of any change to materials, chemical formulations, or process chemistry that would affect the compliance status of any document on file. Treat a material change notification as a trigger for certificate re-issuance — not just a record update.
🔬Commission periodic third-party analytical verification
For products sold into regulated markets at significant volume, commission periodic third-party analysis on sample boards — not just at initial qualification but at least annually during production. The objective is to detect any drift between the manufacturer's declared compliance status and the actual composition of current production boards. Material substitution, process chemistry drift, and upstream supplier changes can all introduce compliance gaps that self-declarations will not reveal.
📡Monitor regulatory changes proactively
Assign responsibility for regulatory monitoring to a specific person or function. Track: ECHA SVHC candidate list updates (published at echa.europa.eu, typically June and December); RoHS delegated act consultations on restricted substance additions; China RoHS catalogue updates; and relevant regional regulation developments in your target markets. Translate new additions to the SVHC list into an immediate inquiry to your PCB suppliers — do not wait for the annual renewal cycle if a newly added SVHC is a candidate for presence in your boards.
Summary
Environmental compliance for PCBs is a layered, dynamic discipline — not a checkbox that is completed at product launch. The three primary frameworks are: EU RoHS 2011/65/EU (10 restricted substances, requiring a dated compliance certificate covering all materials and all substances); REACH SVHC disclosure (obligation triggered above 0.1% per article, with supply chain communication requirements that are only satisfied by a declaration tied to the current ECHA candidate list version); and halogen-free per IEC 61249-2-21 (where applicable, requiring a certificate with actual measured values — not just a conformance statement). Regional regulations including China RoHS and California Proposition 65 impose additional obligations that cannot be satisfied by EU compliance documentation alone. The practical framework is: specify compliance requirements explicitly in every procurement document; obtain and maintain a complete documentation set from every supplier; require annual re-issuance and immediate re-issuance on material change; and commission periodic third-party analytical verification for critical or high-volume products. A compliance gap discovered by a regulator is almost always a documentation gap — not a physical non-compliance in the materials — and maintaining current documentation is the most cost-effective risk control available.