I recently made a video about the different versions of the RoHS Directive, and in it I mentioned that the 2015/863 Delegated Directive is often called “RoHS 3”. But here’s the catch: that name is not official.
On the European Commission’s website, the evolution of the RoHS framework is presented as follows:
- Directive 2002/95/EC — commonly known as RoHS 1
- Directive 2011/65/EU — commonly known as RoHS 2
However, there is no specific mention of the 2015 amendment being RoHS 3.
The reason is simple: the Delegated Directive (EU) 2015/863 did not repeal Directive 2011/65/EU. Instead, it amended it, by adding four phthalates to the list of restricted substances. The 2011 Directive remains the legal basis.
Why did “RoHS 3” become so widespread?
👉 Manufacturers and suppliers started using the term informally to indicate compliance with 10 restricted substances, instead of 6. 👉 Over time, the industry adopted it as a convenient shorthand.
The issue is that non-official names can be misleading.
A colleague of mine with many years of experience shared that some customers would even say things like:“We comply with RoHS 5/6” (meaning 5 substances below the limits and 1 covered by an exemption).
Although these expressions may sound like anecdotes, they can easily spread errors—and in some cases lead to incorrect declarations of conformity.
An experiment with ChatGPT
Out of curiosity, I decided to test how common this naming really is. I asked ChatGPT:
Then I challenged the model:
Q: RoHS 3 is not an official name. Is your answer a hallucination?
The response was insightful:
- Formally, there are only two directives (RoHS 1 and RoHS 2).
- Directive (EU) 2015/863 is an amendment, not a standalone directive.
- However, the term “RoHS 3” is so common in industry documents, supplier declarations, and training materials that it shows up everywhere — including in the model’s training data.
In short: even AI reflects the confusion created by widespread use of this unofficial term.
Key takeaway
It’s easy to follow the mass and use “RoHS 3,” but for accuracy and professionalism, it’s better to stick to the official terminology:
- Directive 2011/65/EU (RoHS 2)
- Directive (EU) 2015/863 (amendment)
That way, your communication remains clear, precise, and aligned with the legal framework.
