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Mon Dec 18 2023 | 2 min read

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If you're manufacturing or distributing electronic devices in California — and still think their RoHS law is "just like the EU’s" — you're missing the plot.

California’s RoHS regulation is narrower, stricter in scope, and very real in enforcement. And it’s been active since January 1, 2007. If your products have a display screen larger than 4 inches and contain lead, cadmium, or other banned substances — you're in the danger zone.

Let’s unpack what California RoHS means for your compliance checklist in 2025.

What is California RoHS?

California RoHS is a state-level environmental regulation modeled on the EU RoHS Directive 2002/95/EC. It restricts the use of four hazardous heavy metals in covered electronic devices (CEDs).

Key difference from EU RoHS: California RoHS only applies to video display devices >4 inches diagonally — not all electrical/electronic equipment.

California RoHS: Restricted Substances (Homogeneous Material Level)

california RoHS restricted substances.PNG

California RoHS Lab Testing & Documentation

Manufacturers must:

  • Conduct substance testing at the homogeneous material level
  • Submit annual reports to the California Integrated Waste Management Board (CIWMB) if any device contains restricted substances
  • Maintain test reports and technical documentation for inspection

If you don’t test, label, and report — you’re vulnerable to enforcement.

What’s a Covered Electronic Device (CED)?

Any product with a video display over 4 inches, including:

  • CRT Devices (TVs & Monitors)
  • LCD TVs, laptops, portable DVD players
  • Plasma TVs

The rule? If the display can’t be easily removed and the screen is >4", it’s a CED.

Categories_of_Covered_Electronic_Devices_Under_RoHS.jpg

California RoHS Exemptions

Some products are explicitly exempt, including:

  • Video displays in motor vehicles (and their replacement parts)
  • Industrial/medical monitoring or control equipment
  • Household appliances with integrated video displays (e.g., refrigerators, ovens)
  • Products no longer considered CEDs

California RoHS Exemptions.jpg

If you're unsure about applicability, get a legal opinion or consult a notified body.

California Lighting Efficiency and Toxics Reduction Act

Beyond RoHS, California has banned inefficient and toxic lighting:

  • Compact fluorescent lamps (CFLs) banned as of Jan 1, 2024
  • Linear fluorescent lamps banned as of Jan 1, 2025

This act focuses on energy efficiency and toxic substance reduction in lighting — reinforcing California’s aggressive stance on sustainability.

California RoHS vs. EU RoHS

california rohs vs eu rohs.PNG

💡 TL;DR: California RoHS is more focused, less updated, but still enforced.

Don’t Risk Non-Compliance. Let Acquis Handle It.

If you manufacture or sell CEDs in California — RoHS is not optional. You need reporting, documentation, and material traceability.

Acquis helps you:

  • Flag high-risk BOMs & suppliers
  • Automate testing & declarations
  • Track compliance by substance + material
  • Generate audit-ready reports for CIWMB

Let Acquis handle the substance limits — you focus on the product launch.

Schedule your free demo today and see how effortless compliance can be.

Speak to Our Compliance Experts