Printed circuit board assemblies sit at the core of modern electronics. They support everything from consumer devices to mission-critical defense systems. Yet, behind every compliant PCB assembly is a regulatory framework that determines where it can be built, who can access it, and how it may be sold.

In the United States, ITAR and RoHS represent two very different, but equally important, compliance requirements for turnkey PCB assembly. One protects national security. The other safeguards environmental and human health. For OEMs and engineers, understanding how these regulations differ, overlap, and affect manufacturing decisions is essential.

This comparative guide explains ITAR vs. RoHS in the context of U.S. PCB assembly, outlines practical compliance requirements, and highlights how manufacturers manage both standards without disrupting production or market access.

Understanding the Purpose Behind Each Regulation

What ITAR Regulates in PCB Assembly

ITAR (International Traffic in Arms Regulations) governs the manufacture, handling, and export of defense-related technology. Administered by the U.S. Department of State through the Directorate of Defense Trade Controls (DDTC), ITAR exists to prevent unauthorized foreign entities from accessing sensitive military technologies.

In PCB manufacturing, ITAR applies when a circuit board assembly is specifically designed for defense or aerospace systems listed on the U.S. Munitions List. Importantly, ITAR does not only apply to the physical board. Design files, schematics, netlists, and test data are also subject to regulation.

What RoHS Regulates in PCB Assembly

RoHS (Restriction of Hazardous Substances) limits the use of specific hazardous materials in electrical and electronic equipment. Its goal is to protect the environment and reduce risks associated with the manufacturing, use, and disposal of electronics.

RoHS focuses on materials and chemistry, not national security. It restricts substances such as lead, mercury, cadmium, and certain flame retardants. While RoHS originated in the EU, it has become a de facto global requirement for electronics sold internationally, including in parts of the U.S.

ITAR vs. RoHS: Key Differences at a Glance

What ITAR Requires From U.S. PCB Assembly Providers

ITAR compliance reshapes how PCB assembly operations are structured.

Core requirements include:

• DDTC registration before manufacturing ITAR-controlled assemblies
• U.S.-person-only access to designs, production, and inspection
• Secure IT infrastructure to prevent unauthorized data access
• Export licensing for any transfer of controlled data or hardware
• Detailed recordkeeping for audits and traceability

These requirements directly influence hiring practices, facility layout, and data-handling procedures. Offshore or mixed-access manufacturing environments are not viable for ITAR programs.

What RoHS Requires From PCB Assembly Operations

RoHS compliance affects materials, sourcing, and process control rather than personnel or data access.

Typical RoHS requirements include:

• Lead-free solder alloys such as tin-silver-copper
• RoHS-compliant laminates, finishes, and components
• Supplier material declarations and Certificates of Conformance
• Lot-level traceability for compliant builds
• Verification testing, often using XRF analysis

Unlike ITAR, RoHS allows global manufacturing, but only when every material in the bill of materials meets regulatory thresholds.

How U.S. Manufacturers Manage Both ITAR and RoHS

Many U.S. PCB assembly providers support programs that require both ITAR and RoHS compliance, particularly for defense systems intended for allied or international use.

Facility-Level Controls

• ITAR: Restricted production areas, controlled access, secure data systems
• RoHS: Dedicated lead-free assembly lines and validated reflow profiles

Documentation and Traceability

• ITAR: Access logs, export records, technical data controls
• RoHS: Material declarations, compliance certificates, batch records

Systems and Automation

ERP and MRP platforms help track component origins, manage documentation, and maintain compliance evidence across both regulatory frameworks.

Real-World Compliance Scenarios

Defense Electronics Requiring ITAR Controls

A missile guidance RF board must be assembled entirely within a registered U.S. facility. All design files remain on secure servers, accessed only by U.S. persons. Even subcontract testing is restricted to approved domestic partners.

Consumer Electronics Requiring RoHS Compliance

A consumer electronics OEM sources components globally but verifies RoHS conformity through supplier audits and documentation. Lead-free assembly processes ensure access to EU and international markets.

Common Pitfalls OEMs Should Avoid

• Assuming RoHS compliance is sufficient for defense programs
• Sharing ITAR-controlled design files with offshore teams
• Failing to collect updated RoHS certificates from component suppliers
• Working with vendors who claim compliance without verification

Early validation and supplier vetting prevent costly redesigns, shipment delays, and regulatory violations.

Strategic Takeaways for Engineers and Procurement Teams

• Address ITAR and RoHS requirements during design, not after release
• Maintain an approved supplier list with documented compliance
• Train teams regularly on evolving regulatory updates
• Treat compliance as part of product risk management, not overhead

Compliance Confidence With a Reliable Supplier

ITAR and RoHS compliance are not interchangeable. Each serves a distinct purpose, and both shape how PCB assemblies are designed, built, and delivered. For OEMs operating in regulated markets, compliance is inseparable from product viability.