TDK Electronics · TDK Europe


All herein contained statements only refer to electronic components manufactured by TDK Electronics.

1. Hasn’t RoHS III already been published?

No. There is currently no RoHS III. Directive 2011/65/EU continues to be referred to as RoHS II, even if it has been amended by Directive (EU) 2015/863.

The European Commission is planning a new version which shall be titled RoHS III, but this is expected to appear in 2022/2023.

2. Are components subject to the RoHS Directive?

Since July 22, 2019, all categories of electrical and electronic equipment (EEE) have been subject to the Directive.

Directive 2011/65/EU does not directly apply to passive components. It is based on the content by weight and restriction of substances in finished products and only indirectly affects the product’s individual parts. TDK Electronics manufactures components that are used in equipment which comes under this Directive.

Our RoHS information about TDK Electronics products provides information on which of our currently offered components are RoHS-compatible; this can be found at:

3. What has changed lately in terms of the RoHS regulations?

RoHS II contains several changes for manufacturers of electrical and electronic equipment (EEE). The most important changes from RoHS I are:

1. The scope

RoHS II comprises a gradual expansion of the requirements to all electrical and electronic equipment (EEE), cables and spare parts with regard to full conformity as of July 22, 2019.

RoHS II (Article 3) clarifies important definitions such as “homogeneous material”.

2. Ban on new substances

The Commission performs a review of the list of restricted substances at regular intervals.

3. Exemptions

RoHS II contains clear and more transparent regulations on the granting, renewing and revoking of exemptions.

4. Coherence with other EU legislation

RoHS II is part of the new legislative framework and thus affects CE marking and declarations of conformity (including the harmonized EN 50581 standard).

4. What is the difference between RoHS 6 and RoHS 10?

On March 31, 2015, the delegated Directive (EU) 2015/863 saw the prior restriction of the following six substances (RoHS 6):

  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Hexavalent chromium (Cr VI)
  • Polybrominated biphenyls (PBB)
  • Polybrominated diphenyl ethers (PBDE)
  • expanded by another four to a total of ten substances (RoHS 10):
  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

5. Are there exemptions to the RoHS?

There are some exceptional regulations for certain equipment groups, applications, components and materials. In these special cases, higher limit values apply.

The exact list of exemptions is provided in Article 4, Annex III and Annex IV of Directive 2011/65/EU.

These exemptions are all of a limited period, but some can be extended or altered by making the relevant application to the EU Commission.

6. What happens if the limited period of an RoHS exemption is about to expire?

The RoHS exemptions only end if no further applications for extension are made or if all applications for extensions have been rejected.

Applications must be submitted to the Commission at least 18 months before the exemption expires.

In accordance with Article 5 (5) sentence 3 of the RoHS Directive, the exemptions that are subject to applications for renewal continue to apply beyond the actual expiration date, until the Commission has decided on the applications.

Furthermore, Article 5 (6) of the RoHS Directive grants a further transition period of a minimum of 12 and a maximum of 18 months from the date of the decision for applications that have been submitted on time, if the renewal applications are rejected.

If the applications are approved, a new expiration date will be set for the relevant exemption.

7. How do RoHS and CE marking relate to each other?

For equipment that comes within the scope of RoHS II, compliance with the RoHS Directive has been a prerequisite in order to affix a CE mark since 2011. Compliance with the RoHS Directive must be confirmed in the EU declaration of conformity.

8. Does RoHS also apply if I’m not selling any equipment in the EU?

The RoHS Directive applies for all electrical and electronic equipment that is placed on the market in the EU, regardless of who placed it on the market.

9. What is the difference between RoHS and REACH?

REACH is a very broad statutory regulation which controls the risks in conjunction with chemical substances throughout their entire life cycle whereas RoHS is a product-specific statutory regulation which focuses on dangerous substances in electrical and electronic equipment.

REACH applies to all substances (mixtures or articles), including the substances in electrical and electronic equipment that fall under the scope of RoHS.

When establishing the conditions for placement on the market of electrical and electronic equipment, RoHS takes into account waste management operations and recycling, which have a greater potential impact in terms of exposure to humans and the environment than the manufacturing process.

Although their scopes do overlap somewhat, these regulations have been designed to complement each other.

10. Which RoHS-II-compatible components will continue to contain lead?

RoHS information about TDK Electronics products provides information on which of our currently offered components will continue to contain lead and are RoHS-compatible and which exemption is applicable; this can be found at:

11. Are there TDK Electronics components which contain other RoHS-relevant substances, apart from lead?

The elements mercury, cadmium and its compounds, chromates, polybrominated biphenyls (PBB), polybrominated diphenyl ethers, in particular octa- and pentabromodiphenyl ethers, Bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP) may only be present in trace amounts under the legally defined tolerance limits.

12. Are RoHS-II-compatible, approved samples available?

Samples are available (see information on RoHS II and lead-free products from TDK Electronics).

13. Are RoHS-II-compatible components specially marked at TDK Electronics?

The components are not marked, however they can be identified using the date code. We do identify our shipments with the text “RoHS compatible” on the delivery documents and the barcode product label (BPL) if the products are RoHS-II-compatible.

14. Are the ordering codes being changed in the course of the transition to RoHS II compatibility?


15. Have the electric specifications for RoHS-II-compatible components changed?


16. It is impossible to ban lead in some components. Which components are these?

All components can be converted so that they have lead-free terminations.

17. Since when has TDK Electronics offered components with RoHS-II-compatible terminations?

TDK Electronics switched to lead-free components in 2001. Newly developed items are supplied with lead-free terminations (see information on RoHS II and lead-free products from TDK Electronics).

18. What material are the terminations made of?

The lead-free terminations are generally made from Sn100 (pure tin) with a nickel diffusion barrier (other coatings can be used for certain components).

19. Do RoHS-II-compatible components require a higher soldering temperature?

Process-related temperature adjustments in the lead-containing process may occur. For lead-free processes, new temperature profiles generally need to be implemented due to the solder being used.

20. Are there differences in processing tin/lead soldering alloys and lead-free soldering alloys?

Due to the high melting points of lead-free solder, the soldering profiles must be adjusted accordingly. Notes on this can be found in IEC Standard 60068-2-58, for example.

21. Are there limitations regarding the shelf life of products?

In terms of shelf life and solderability, there is no known difference between terminations which are lead-free and those which contain lead. Shelf life is usually heavily dependent on the storage conditions and environmental influences (temperature, humidity).

22. Who is the contact person for topics concerning RoHS II and the current European legislation regarding product-related environmental protection?

Please contact your original sales partner (TDK sales office or distributor) with your query. They can help you and may forward your query to our internal specialist departments.