RoHS Compliance Guide for Musical Instrument Makers – UK & EU

Introduction

If your instruments contain electronics—pickups, active preamps, onboard tuners, pedals, or amps—then RoHS applies to you. RoHS rules limit the use of certain hazardous substances in electrical and electronic equipment.

Disclaimer: This guidance is based on our experience in the musical instruments and compliance industries. It does not constitute legal advice.


What is RoHS?

RoHS stands for Restriction of Hazardous Substances. It sets maximum levels for certain substances in electrical and electronic products. The main aim is to reduce environmental and health risks from harmful materials.


Who Does It Affect?

RoHS applies to almost all products that have electrical or electronic components, including:

  • Electric guitars and basses with pickups (active or passive)

  • Effects pedals and rack gear

  • Amplifiers and powered speakers

  • Any instrument with batteries, power supplies, or digital circuits


Restricted Substances and Limits

Under RoHS, products must not exceed:

  • Lead (Pb): 0.1%

  • Mercury (Hg): 0.1%

  • Cadmium (Cd): 0.01%

  • Hexavalent chromium (Cr6+): 0.1%

  • Polybrominated biphenyls (PBB): 0.1%

  • Polybrominated diphenyl ethers (PBDE): 0.1%

  • Four phthalates (DEHP, BBP, DBP, DIBP): 0.1%


Your Main RoHS Responsibilities (Guidance Only)

1. Use Compliant Components

Buy parts (pickups, switches, pots, jacks, PCBs, wiring) from suppliers who can confirm RoHS compliance—ideally with written certification.

2. Keep Records

Maintain a technical file that includes:

  • Parts list (BOM)

  • Supplier declarations or test reports

  • Assembly drawings and wiring diagrams

  • Any third-party testing you’ve commissioned

3. Declaration of Conformity

If your product requires CE or UKCA marking, RoHS compliance should be included in your Declaration of Conformity.

4. Marking and Labels

While RoHS itself does not require a special logo, products covered by CE/UKCA must follow those marking rules.


UK vs EU RoHS

  • EU: Directive 2011/65/EU (and later amendments) applies across member states and Northern Ireland.

  • UK (Great Britain): Has its own RoHS Regulations, which currently match EU limits but are separate legislation.


Common Mistakes to Avoid

  • Using parts without proof of RoHS compliance

  • Assuming “low voltage” means RoHS doesn’t apply—it does

  • Not keeping documentation for the required retention period (usually 10 years)

  • Forgetting to update files when changing suppliers or components


Quick RoHS Checklist

Requirement Guidance Action
Source Components Wisely Use suppliers with RoHS declarations
Keep a Technical File Store BOM, test reports, and drawings
Include in DoC Add RoHS compliance to your Declaration
Keep Records Long-Term Retain for at least 10 years

Where to Get Support

  • Our Template Pack for electric instruments includes ready-to-use RoHS record sheets.

  • Our Free Guide explains RoHS basics for builders new to compliance.

Reminder: This is guidance based on industry experience, not legal advice.