RoHS Category 11: The Catchall Category

Understanding Restriction of Hazardous Substances in Electronics

Table of Contents

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The RoHS directive, issued in the European Union, restricts the use of several hazardous materials in electronic and electrical equipment (EEE). All EEE products sold in the EU must comply with RoHS.

The RoHS directive currently limits the use of ten hazardous substances within EEE in the European Union. 

The ten hazardous materials included in RoHS must be used in electronics only below specific thresholds. The allowable amount for each substance except cadmium is 1000 ppm. The allowable amount for cadmium is 100 ppm.

The materials include:

Which Products Does RoHS Restrict?

It is important that manufacturers determine whether their product fits the definition of EEE, because all EEE, including smaller components, is subject to RoHS compliance requirements. RoHS defines EEE as: “equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields” (Directive 2011/65/EU). 

RoHS breaks down restricted EEE into 11 categories. The current categories are the result of one original directive and two additions known as RoHS 2 and 3. Read more: The Difference Between RoHS 1, 2 and 3

The current categories are:

  • Category 1: Large household appliances (eg. refrigerators)
  • Category 2: Small household appliances (eg. hair dryers)
  • Category 3: Computing & communications equipment (eg. computers)
  • Category 4: Consumer electronics  (eg. televisions)
  • Category 5: Lighting (eg. lamps)
  • Category 6: Power tools (eg. electric drills)
  • Category 7: Toys, leisure and sports equipment (eg. electronic dolls)
  • Category 8: Medical devices and equipment, such as in-vitro diagnostic devices, known as IVDs
  • Category 9: Monitoring and control instruments, such as thermostats and smoke detectors
  • Category 10: Automatic dispensers (eg. vending machines)
  • Category 11: Any EEE not covered in the previous ten categories. 

Categories 8 and 9 were added by RoHS 2 (Directive 2011/65/EU), and Category 11 was added by RoHS 3 (Directive EU 2015/863). The other categories were included in the original RoHS directive. As of July 22, 2021 all EEE under every category must comply with RoHS.

What Is Included in RoHS Category 11?

RoHS Category 11 acts as a ‘catchall’ category, as it includes all EEE that is not covered in the previous ten categories. The inclusion of category 11 in RoHS greatly expanded the scope of RoHS, as any product that falls under the definition of EEE must comply with RoHS.

Products that are not included in the previous categories but are added by category 11 include, but are not limited to:

e-bike - rohs category 11
Electric bike covered under RoHS category 11
  • Two-wheeled electric vehicles
  • Electronic nicotine delivery systems (ENDS) such as e-cigarettes and vapes
  • Electrical cables of less than 250 volts
  • Non-finished cables such as cable reels without plugs

This list is not exhaustive, and manufacturers must assess their EEE on a case by case basis to determine if it is within the scope of products regulated by RoHS.


While RoHS Category 11 technically expands RoHS to all EEE, the directive still includes several exemptions.

RoHS Exemption Categories

RoHS includes categories of EEE that are exempt from regulation:

  • Equipment necessary for security, including arms, munitions and material intended for military purposes
  • Equipment designed to be sent into space
  • Large -scale stationary industrial tools
  • Large-scale fixed installations
  • Means of transport for people or goods
  • Non-road mobile machinery exclusively for professional use
  • Active implantable medical devices
  • Permanently installed photovoltaic panels to produce solar energy
  • Equipment designed for business-business research
  • Equipment that is designed to be installed in another type of equipment that is excluded under RoHS.

Any EEE that falls under one of these definitions is not subject to RoHS regulation.

It is important that manufacturers are certain that their non-compliant product is included under one of the exempt categories, as placing a non-exempt, non-RoHS compliant product on the market can result in penalties. 

Restricted Substances with No Safe Substitutions

RoHS also includes exemptions to allow use of hazardous substances only in specific applications, such as in specific types of devices. Manufacturers can apply for these exemptions when no safe alternative to the restricted substance can be found and the product cannot be made otherwise.

For example, the use of hexavalent chromium above 1000ppm is permitted in specific devices, such as spare parts for x-ray systems placed on the EU market.

A full list of substances exempt from restrictions when used in specific applications can be found on the European Chemicals Agency website.

The RoHS directive pushes companies to search for alternative substances and processes that are RoHS compliant, even while using the original, exempted material. If a viable alternative is not found, extension of the exemption is possible.

To encourage innovation, these specific exemptions are temporary and expire on a set date. Manufacturers must remain aware of exemption expiration dates so as not to continue use of a material or application that is no longer exempt.

Impact of RoHS Category 11

Because of its wide scope, category 11 has widely spread impacts. Category 11 greatly expanded the reach of RoHS regulations to include products and manufacturers that may not have been previously affected. 

Increased Price of Production

The inclusion of category 11 may increase prices for EEE, as manufacturers must take steps to ensure RoHS compliance. Manufacturers of this equipment must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, testing products and ensuring RoHS compliance may be costly.

Buyers of EEE may also face increased prices as a result of increased production costs.

Increased Scientific & Technological Innovation

However, increased costs come hand in hand with increased innovation. RoHS pushes scientific and technological progress in the electronics industry, as EEE products and production processes are redesigned to exclude restricted substances.

Decreased Risk to the Environment and Human Health

By expanding RoHS to all EEE, Category 11 reduces the amount of hazardous substances used in manufacturing of electronics. The restricted materials listed in RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of EEE that can be recycled safely.

Exposure to RoHS-restricted substances can also harm human health. By expanding the scope of products included under RoHS, category 11 works to reduce the chance of exposure to harmful substances, both when using EEE products and when EEE products are manufactured or recycled.

Read more about the impact of RoHS: What is RoHS?

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