1. What is RoHS, and does it apply to cables?
RoHS stands for the EU’s “Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment.” The current version is 2011/65/EU (known in the industry as RoHS 2); it entered into force on July 21, 2011, and required transposition into national law by EU member states by January 2, 2013. The directive restricts the use of hazardous substances in electrical and electronic equipment that relies on electric currents or electromagnetic fields to function and operates at voltages not exceeding 1,000 V AC or 1,500 V DC.
It is important to note that cables and spare parts were brought within the scope of RoHS starting July 22, 2019 (including PV cable products such as H1Z2Z2-K and PV1-F under the EN 50618 standard).
Consequently, PV DC and AC cables exported from China to the EU must comply with RoHS restrictions; otherwise, they cannot be legally placed on the EU market.
II. 10 Restricted Substances and Limit Values
In accordance with Annex II of the Directive and the amendment by EU Delegated Directive (EU) 2015/863, ten substances are currently restricted, with limits calculated as a weight percentage of homogeneous materials: lead (0.1%), mercury (0.1%), cadmium (0.01%), hexavalent chromium (0.1%), polybrominated biphenyls (PBB) (0.1%), polybrominated diphenyl ethers (PBDE) (0.1%), and four phthalates added by (EU) 2015/863—DEHP (0.1%), BBP (0.1%), DBP (0.1%), and DIBP (0.1%). Cadmium has the strictest limit (0.01%), and the concept of “homogeneous material” is crucial: limits apply to each individual material layer within the product rather than the average value of the entire cable.
If any layer—such as the insulation, sheath, conductor plating, or color masterbatch—exceeds the limit, the entire cable is deemed non-compliant; attempting to mask an excess in a specific material through “overall dilution” is not legally valid. Key areas for inspection include the insulation and sheath materials and the tinned copper conductors of photovoltaic cables.
The wording of lead exemption clauses (covering steel, aluminum, and copper alloys, glass/ceramics, high-temperature solders, etc.) has been updated effective July 1, 2026, and most subsequent exemption entries are set to expire in 2027; cable components containing lead-based plating or solder must be screened and replaced in advance.
III.
Compliance Path for Photovoltaic Cables: RoHS and CE
RoHS 2 is a directive linked to CE marking requirements: companies must demonstrate product compliance and complete the CE marking process before entering the EU market; this path involves four steps.
Step 1: Compile technical documentation and assess the risk of hazardous substances in the product and supply chain in accordance with EN IEC 63000. Step 2: Conduct material testing or obtain material declarations from suppliers; testing methods must comply with the EN IEC 62321 series of standards. Step 3: Draft the EU Declaration of Conformity (DoC) in the format specified in Annex VI of the Directive. Step 4: Affix the CE mark to the product.
In practice, exporting enterprises may request RoHS test reports and material declaration forms from upstream cable manufacturers while conducting their own random sampling tests on the finished cables.
Importers and distributors also bear compliance responsibilities: importers must ensure that the manufacturer has fulfilled the aforementioned obligations, retain a copy of the Declaration of Conformity, and provide technical documentation upon request by market surveillance authorities.
IV.
Distinction from Photovoltaic Modules: Modules Permanently Excluded
A common point of confusion regarding the scope of RoHS applicability concerns photovoltaic modules themselves. The Directive explicitly lists photovoltaic panels as permanently excluded, and the European Commission maintains a strict interpretation of this exclusion—meaning the modules themselves do not require RoHS compliance.
However, Balance of System (BOS) components—such as cables, connectors, junction boxes, and inverters—do not benefit from this exclusion and must comply with RoHS regulations.
Consequently, for photovoltaic system projects exported to the EU, while modules are exempt from RoHS, the associated photovoltaic cables must possess evidence of RoHS compliance and bear the CE mark; otherwise, the goods risk being pulled from the market following spot checks by regulatory authorities during customs clearance or project acceptance.
Exporters should clearly explain the distinction—”modules exempt, components mandatory”—to clients during the quotation and documentation preparation stages to avoid confusion.
V. Practical Considerations and Trends
In addition to RoHS, exporting photovoltaic (PV) cables to the EU requires attention to three concurrent requirements: First, the REACH regulation, which involves obligations regarding Substances of Very High Concern (SVHC) declarations and the SCIP database; RoHS and REACH apply in parallel and cannot substitute for one another. Second, product standards; DC cables must obtain relevant certifications—such as EN 50618 (1500V H1Z2Z2-K) or TÜV 2PfG 1169 (1000V PV1-F)—as RoHS addresses only hazardous substances and does not replace performance or safety certifications. Third, exemption validity periods;
the EU reviews its exemption list every four years, and a batch of lead exemptions is set to expire on December 11, 2026. Lead-containing materials that are not substituted before this deadline will no longer be covered by the exemption.
Enterprises are advised to establish a hazardous substance control log, regularly monitor changes to the EU exemption list, and re-evaluate compliance following any product changes, thereby shifting RoHS compliance from a one-time testing event to a process of continuous management.
Conclusion
RoHS requirements for PV cables exported to the EU can be summarized as follows: cables are within scope, components may be exempt, ten substances are subject to limits, assessment is based on homogeneous materials, and CE marking is mandatory.
To ensure long-term compliant sales in the EU market, companies must secure dual compliance with RoHS and product standards (such as EN 50618), control the ten regulated substances (including lead and cadmium) at the homogeneous material level, prepare comprehensive technical documentation and Declarations of Conformity, and closely monitor the expiration schedule for lead exemptions between 2026 and 2027.
