RoHS Writes Its Own Definition of the Word "Cable"

October 6, 2026

Ask a cable supplier for a RoHS statement and one arrives, usually a paragraph saying the product conforms. What the paragraph is normally missing is the two things the directive actually turns on, and neither is a test result. The first is whether the cable is in scope at all, which the directive decides by defining the word cable itself. The second is what the percentage is measured against, and for a finished cable the answer is not the cable.

Both questions are answered in the legal text, in definitions the directive writes for its own purposes. Read them once and a conformity statement becomes easy to audit.

The directive defines the word "cable"

RoHS is short for the restriction of the use of certain hazardous substances in electrical and electronic equipment; the current instrument is Directive 2011/65/EU as amended, and its definitions article contains an entry most product regulations lack.

A cable, for the purposes of the directive, means all cables with a rated voltage of less than 250 volts that serve as a connection or an extension to connect electrical and electronic equipment to the electrical outlet, or to connect two or more items of such equipment to each other.

Two conditions sit inside that sentence, and a cable has to satisfy both.

Condition	What it asks
A rated voltage of less than 250 volts	The rating on the cable, not the voltage it happens to see in service
A connecting or extending role	The cable must serve to connect equipment to the outlet, or to connect two or more items of equipment to each other

The second is the one that surprises people. The definition is functional: it describes a cable by what it does in a system rather than by how it is built, so the same construction can be inside the definition in one application and outside it in another.

The directive then names cables expressly in its prohibition, requiring that equipment placed on the market, including cables and spare parts for its repair, reuse, updating of functionalities or upgrading of capacity, does not contain the substances in its second annex. The word is there deliberately: it forecloses the argument that a passive interconnect is not really equipment.

There is also a dated carve-out. The prohibition does not apply to cables or spare parts for equipment placed on the market before 1 July 2006, which is why a statement can be unnecessary on an old product even though the same cable would need one today.

The two conditions in the definition

Scope is settled twice: the category, then the exclusion list

Being a cable with a definition is not the end of the scope question either. The directive applies to equipment falling within the categories in its first annex, and it then removes a list of things from scope altogether.

Excluded from scope
Equipment necessary for the essential security interests of Member States, including arms, munitions and war material for specifically military purposes
Equipment designed to be sent into space
Equipment designed and to be installed as part of an excluded type of equipment, which can only function as part of it and can only be replaced by the same specifically designed equipment
Large-scale stationary industrial tools
Large-scale fixed installations
Means of transport for persons or goods, with an exception for certain electric two-wheel vehicles
Non-road mobile machinery made available exclusively for professional use
Active implantable medical devices
Photovoltaic panels intended for use in a system designed, assembled and installed by professionals for permanent use at a defined location
Equipment designed solely for research and development and made available only business to business
Pipe organs

For a cable the interesting rows are the industrial ones. A cable that becomes part of a large-scale fixed installation, or of a machine that is itself excluded, leaves scope the same way the installation does, because of where it ends up rather than what it is.

The directive also states what it does not displace. It applies without prejudice to Union legislation on safety and health and on chemicals, in particular Regulation (EC) No 1907/2006, which is its way of saying it is one regime among several. A declaration under this directive does not answer the separate chemical regime.

The threshold is a concentration in a material, not in a product

Here is the clause that decides how a cable is tested. The directive provides that no more than the maximum concentration value by weight in homogeneous materials as specified in its second annex shall be tolerated.

The denominator is a homogeneous material. And the directive defines that too: a homogeneous material means one material of uniform composition throughout, or a material consisting of a combination of materials that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.

Read that second limb carefully, because it is a test rather than a description. The question is not whether a part looks like one material or was supplied as one, but whether it can be taken apart by ordinary mechanical means. If it cannot, it is one homogeneous material for the purposes of the threshold, whatever the supplier calls it.

Two consequences follow. A percentage quoted against the finished cable means nothing, because the finished cable is not the unit of assessment. And two suppliers can test the same construction and report different percentages without either being wrong, if they divided the cable into different sets of materials.

The directive adds that the detailed rules for complying with the maximum values are to take account of, among other things, surface coatings. A coating is thin, it does not come off by grinding without being destroyed, and it is often where a restricted substance would sit.

What a cable’s homogeneous materials actually are

Applying the mechanical separation test to an ordinary cable produces a longer list than most people expect, and each line is compared with the limit separately.

Material	Where it comes from	Separable by ordinary mechanical means
Conductor metal	Stranded or solid copper, or aluminum	Yes, as a metal
Plating	Tin, nickel or silver on the strands	No. It comes off with the metal or not at all, and it is assessed with the surface it coats
Insulation compound	Around each conductor	Yes, by stripping
Filler and tape	Between the cores	Usually yes
Shield	Foil, braid or drain wire	Yes, though a bonded foil is the awkward case
Jacket compound	The outer layer	Yes
Marking ink	Printed or embossed on the jacket	No, in the sense that it is not removed to be assessed separately, and it is a surface coating on the jacket
Adhesive	Laminates and bonded foils	Depends on whether the bond can be broken mechanically

The practical value of the table is the middle column. A material that cannot be separated is assessed together with whatever it is attached to, so the plating and the copper are not two materials, and the ink and the jacket are not two materials. That is not a loophole, because it cuts both ways: the parent material inherits the concentration of whatever is fused to it.

What counts as one homogeneous material

The material people forget is the marking ink

A declaration built from the conductor, insulation and jacket is missing the layer that is easiest to overlook: the ink is thin, it is applied to the outside of the finished cable, and it has to survive everything the jacket survives.

Pigments and their carriers are formulated with metals and with organic compounds, so a color change is a formulation change even when nothing else moves. And the ink is a surface coating, which the directive says the detailed rules take into account. A cable compliant in one color is not automatically compliant in another.

Cadmium is an order of magnitude tighter

The second annex is short, and one line in it is not like the others.

Restricted substance	Maximum concentration by weight in homogeneous materials
Lead	0.1 percent
Mercury	0.1 percent
Cadmium	0.01 percent
Hexavalent chromium	0.1 percent
Polybrominated biphenyls	0.1 percent
Polybrominated diphenyl ethers	0.1 percent
Bis(2-ethylhexyl) phthalate, DEHP	0.1 percent
Butyl benzyl phthalate, BBP	0.1 percent
Dibutyl phthalate, DBP	0.1 percent
Diisobutyl phthalate, DIBP	0.1 percent

Cadmium is limited to a tenth of the figure that applies to everything else, which makes it the substance most likely to fail on a cable that was designed with the other nine in mind. It appears in plating, in pigments and in stabilizer systems, and it is the reason a cadmium check has to be run against the material rather than inferred from the absence of the other nine.

The four phthalates on the list arrived later than the metals, and the annex notes that their restriction applies to medical devices and to monitoring and control instruments from 22 July 2021. A cable specification written before that date and reused since can therefore be carrying a compound position that was adequate when it was written.

The ten limits, and cadmium

An exemption is a dated permission, not a property

Annexes III and IV of the directive hold the exemptions, and the important thing about them is that they expire. The directive sets a maximum validity period for the exemptions listed as at 21 July 2011, of five years from the dates in the prohibition clause and seven years for the categories covering medical devices and monitoring and control instruments, with a shorter period applying where one is specified. Where an application for renewal is made, the validity continues until a decision is taken on the application.

Two features of the arrangement change how a declaration should be read. The first is that an exemption is tied to an application rather than to a product family, so a statement saying only "exempt", without an annex and an entry number, identifies nothing. The second protects stock rather than specification: equipment that benefited from an exemption and was placed on the market before it expired may continue to be made available.

For a buyer, the practical form of both points is a question with three parts: which annex, which entry number, and to what date. A supplier who can answer all three is describing a permission. One who cannot is describing a memory of one.

What a compliant statement has to say

Item	Why it belongs in the statement
The instrument and its consolidated version	The directive has been amended many times, and the phthalates and the application dates came in by amendment
The ten substances, by name	A statement of the substance list is the only way to show that the current list was used rather than an earlier one
The unit of assessment, named as homogeneous material	It is the denominator the directive specifies, and a figure against the finished cable is not a figure under this directive
The material inventory used	It is what allows two suppliers’ figures to be compared at all
Which materials could not be mechanically separated	It explains why plating and ink appear in the figures of the material they are attached to
The scope position, including the voltage rating and the connecting role	Both conditions in the definition have to hold for the cable to be a cable under the directive
The exclusion position, where the destination is an excluded application	A cable inside a large-scale fixed installation or a means of transport leaves scope with it
Any exemption claimed, with annex, entry number and expiry date	An exemption is a dated permission and an entry number is how it is identified

FAQ

Does every cable need a RoHS statement?

The directive defines a cable as one with a rated voltage of less than 250 volts that serves to connect equipment to the outlet or to connect two or more items of equipment, and it names cables in its prohibition. A cable that fails either condition, or that ends up in an excluded application such as a large-scale fixed installation, is outside the regime the statement is made under.

Is the 0.1 percent limit measured against the cable?

No. The limit is a maximum concentration by weight in homogeneous materials, and a homogeneous material is defined as one that cannot be separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. A percentage quoted against the finished cable is not a percentage under this directive and cannot be compared with one that is.

Conclusion

Two definitions do most of the work, and both are written by the directive rather than the trade. One defines the word cable, using a voltage ceiling and a functional role, which is why a passive interconnect is named expressly in the prohibition. The other defines a homogeneous material by a mechanical separation test, which is why the percentage is never measured against the finished cable.

Everything else follows. The material inventory gets longer than expected once the test is applied honestly. Cadmium is an order of magnitude tighter than the rest of the list. An exemption is a dated permission that has to be identified by annex and entry number. And the directive says it applies without prejudice to the separate chemical regime, so a document issued under one is not a document issued under the other.

None of this makes a conformity statement harder to write. It makes it specific, which is what lets a buyer check it.

Cable and the material declarations behind it

ZONG Cable supplies HDMI, USB, network, patch cord, fiber, power cord and communication cable and states, before an order, the substance position by material rather than as a single figure for the reel, together with the scope position for the application the cable is going into. Send us the destination application, the voltage rating and the materials you need declared, and we will set out the position against the current list. The range sits under cable, how declarations are assembled for a project is covered in the guide to custom cable projects, the layer-by-layer construction this assessment works through is set out in inside a network cable, conductor substitution is covered in the guide to copper-clad aluminum conductor, the validity of a test report is examined under test report validity, and private-label declarations are fixed under OEM support.

Sources

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 (recast), consolidated text 02011L0065, version of 1 April 2021. Read directly for this article: Article 1 Subject matter; Article 2 Scope, including paragraph 1 applying the Directive to EEE falling within the categories set out in Annex I, paragraph 3 stating that the Directive applies without prejudice to the requirements of Union legislation on safety and health and on chemicals, in particular Regulation (EC) No 1907/2006, and paragraph 4 listing the exclusions, comprising equipment necessary for the essential interests of the security of Member States including arms, munitions and war material for specifically military purposes, equipment designed to be sent into space, equipment designed and to be installed as part of another type of equipment that is excluded or out of scope and which can fulfil its function only as part of that equipment and can be replaced only by the same specifically designed equipment, large-scale stationary industrial tools, large-scale fixed installations, means of transport for persons or goods excluding certain electric two-wheel vehicles, non-road mobile machinery made available exclusively for professional use, active implantable medical devices, photovoltaic panels intended to be used in a system designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications, equipment specifically designed solely for research and development made available only on a business-to-business basis, and pipe organs; Article 3 Definitions, including point (1) defining electrical and electronic equipment and the voltage rating limits of 1 000 volts alternating current and 1 500 volts direct current, point (5) defining cables as all cables with a rated voltage of less than 250 volts that serve as a connection or an extension to connect EEE to the electrical outlet or to connect two or more EEE to each other, and point (20) defining homogeneous material as one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes; Article 4 Prevention, including paragraph 1 requiring Member States to ensure that EEE placed on the market, including cables and spare parts for its repair, its reuse, updating of its functionalities or upgrading of its capacity, does not contain the substances listed in Annex II, paragraph 2 stating that no more than the maximum concentration value by weight in homogeneous materials as specified in Annex II shall be tolerated and that detailed rules for complying with those values are to be adopted taking into account, inter alia, surface coatings, paragraph 3 giving the staggered dates of application, and paragraph 4 providing that paragraph 1 shall not apply to cables or spare parts for the repair, reuse, updating of functionalities or upgrading of capacity of EEE placed on the market before 1 July 2006 and of certain further categories; Article 5 on the adaptation of the Annexes, including the maximum validity periods and the position pending decisions on renewal applications; and Annex II, Restricted substances referred to in Article 4(1) and maximum concentration values tolerated by weight in homogeneous materials, listing lead at 0,1 percent, mercury at 0,1 percent, cadmium at 0,01 percent, hexavalent chromium at 0,1 percent, polybrominated biphenyls at 0,1 percent, polybrominated diphenyl ethers at 0,1 percent, bis(2-ethylhexyl) phthalate at 0,1 percent, butyl benzyl phthalate at 0,1 percent, dibutyl phthalate at 0,1 percent and diisobutyl phthalate at 0,1 percent, together with the note that the restriction of DEHP, BBP, DBP and DIBP applies to medical devices including in vitro medical devices and to monitoring and control instruments including industrial monitoring and control instruments from 22 July 2021. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02011L0065-20210401
ZONG Cable range. https://zh-zong.com/cable/