REGULATIONSROHS

RoHS

A non-EU manufacturer’s obligations effectively fall on you. If you place the equipment under your own name, you are treated as the manufacturer outright.

FALLS ONSUPPLIERBUYER

This one falls on you directly.

THE OFFICIAL ARTIFACT

What the supplier must actually produce.

Not a supplier promise. A technical file built on evidence per homogeneous material, and a declaration you stand behind.

WHO SIGNS IT OFF
Self-declaration. You hold the technical documentation for ten years and produce it on request. No portal, no third-party verification.
REQUIRED ARTIFACT · ROHS6 ELEMENTS
EU declaration of conformity + technical file
DIR. 2011/65/EU · ART. 7, 13 · ANNEXES II, VI · EN IEC 63000
Ten restricted substancesLead, mercury, hexavalent chromium, PBB, PBDE and four phthalates at 0.1%; cadmium at 0.01%.
Per homogeneous materialThe threshold applies to each material, not to the assembled product.
Supplier evidenceDeclarations or test data covering every component.
Technical fileCompiled under EN IEC 63000.
EU declaration of conformityOn the Annex VI model, signed and dated.
CE markingAffixed once the declaration is drawn up.
THE CHARACTERISTIC FAILURE

A supplier declaration arrives, covering the product.

A compliance statement arrives where evidence per homogeneous material was needed.

WHAT USUALLY ARRIVESINSUFFICIENT
Product-level compliance statement
SUPPLIER LETTERHEAD · “ROHS COMPLIANT” · NO TEST DATA
Signed, dated, on company letterhead
Asserts compliance for the finished product
No per-material evidence, no test reports behind it
NOT SUFFICIENT
A statement, not a file. RoHS thresholds apply per homogeneous material, and the authority can ask for what is behind the claim.
WHAT THE REGULATION NAMESSUFFICIENT
Technical file per EN IEC 63000
PER HOMOGENEOUS MATERIAL · TEN SUBSTANCES · TEN-YEAR RETENTION
Evidence per material, covering all ten substances
The four phthalates included, not only the original six
Retained ten years and producible on request
SUFFICIENT
Same product, same components — evidenced at the level the directive actually measures.
THE DELTA: A PRODUCT-LEVEL CLAIM VS EVIDENCE PER HOMOGENEOUS MATERIAL
NEXT MILESTONE · ROHS
LAST VERIFIED 9 AUG 2026
NowIN FORCE
IN FORCECONTINUOUS SINCE 2011
Restriction in force; exemptions expire on rolling dates

Compliance is per homogeneous material and evidenced by technical documentation. Exemption renewals are decided case by case, so an exemption you rely on can lapse.

Does ROHS reach your products?

Find out which of your suppliers can evidence RoHS per material rather than per letterhead.

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