RoHS — Restriction of Hazardous Substances
ROLL Packaging products are not classified as electrical or electronic equipment (EEE) and therefore fall outside the scope of RoHS Directive 2011/65/EU. The applicable heavy metals limits are met through ROLL's compliance with Article 5 of Regulation (EU) 2025/40 (PPWR).
ROLL's position under RoHS
RoHS Directive 2011/65/EU restricts the use of certain hazardous substances in electrical and electronic equipment placed on the European Union market. The scope of the directive is defined in Article 2 and Annex I, and covers EEE categories such as large household appliances, IT and telecommunications equipment, lighting equipment, electrical tools, toys, medical devices and monitoring instruments.
ROLL Packaging products — roll cradle pallets, end plates and flanges, wedges and chocks, cradles and stackers, and metal rack stillages — are industrial packaging components and internal handling equipment. They contain no electrical or electronic functions and are not placed on the market as EEE.
As a result, ROLL products are not subject to the obligations of Directive 2011/65/EU. However, the same heavy metals restricted by RoHS are also limited under Article 5 of Regulation (EU) 2025/40 (PPWR), which applies to packaging materials and is the relevant regulatory framework for ROLL products.
Why RoHS does not apply to ROLL products
Directive 2011/65/EU defines electrical and electronic equipment (EEE) in Article 3(1) 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".
ROLL products do not meet this definition:
- They do not depend on electric currents or electromagnetic fields to perform their intended function
- They do not generate, transfer or measure electric currents or electromagnetic fields
- They are not listed in any of the EEE categories defined in Annex I of the directive
Consequently, ROLL Packaging products are not within the scope of RoHS Directive 2011/65/EU and a formal RoHS compliance declaration is not required for these products.
Heavy metals limits under PPWR Article 5
Although RoHS is not formally applicable, ROLL Packaging declares that the sum concentration of the four heavy metals also restricted by RoHS does not exceed the limits set by Article 5 of Regulation (EU) 2025/40 (PPWR), which represents the applicable regulatory framework for packaging materials in the European Union.
| Heavy metal | Symbol | PPWR Art. 5 limit | ROLL declaration |
|---|---|---|---|
| Lead | Pb | Sum ≤100 ppm | Compliant |
| Cadmium | Cd | Sum ≤100 ppm | Compliant |
| Mercury | Hg | Sum ≤100 ppm | Compliant |
| Hexavalent chromium | Cr VI | Sum ≤100 ppm | Compliant |
The 100 ppm limit applies to the cumulative concentration of lead, cadmium, mercury and hexavalent chromium present in the packaging material. ROLL's declaration is based on supplier documentation collected as downstream user.
Other RoHS-restricted substances
RoHS Annex II also restricts six brominated flame retardants and four phthalates (DEHP, BBP, DBP, DIBP). ROLL declares that these substances are not intentionally used as functional components in the raw materials employed in the manufacturing of ROLL products, on the basis of supplier declarations and technical specifications.
Full heavy metals declaration in PPWR context
Heavy metals compliance is part of ROLL's PPWR Article 5 declaration.
Regulatory references
This declaration is issued with reference to:
- Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS recast), as amended
- Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on Packaging and Packaging Waste (PPWR), Article 5 on substances in packaging
The official text of both legislative acts in all 24 EU languages is available on the EUR-Lex portal at eur-lex.europa.eu.
Disclaimer
The information on this page is provided for guidance only, on the basis of ROLL's most up-to-date knowledge and experience and of declarations received from its raw material suppliers. ROLL cannot assume liability for damage arising from its use. This statement does not constitute any warranty, express or implied. It is intended only for the addressee and cannot be transferred to third parties. All ROLL products are sold subject to the ROLL SNC general sales conditions. This publication replaces all previous versions and is subject to change without notice.