{
  "type": "problem",
  "slug": "b2b-customer-questionnaire",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/b2b-customer-questionnaire/",
  "markdown": "https://www.conphora.com/solutions/problem/b2b-customer-questionnaire.md",
  "title": "A business customer sends a compliance questionnaire",
  "description": "A customer that builds your part into its product asks about RoHS, REACH and traceability. What the law makes you supply and what is set by agreement.",
  "answer": "A business customer that builds your part into its product needs your data for its own declaration. Under the RoHS Directive it must show that the finished equipment meets the substance limits, and REACH obliges you to tell it about candidate-list substances above 0.1 % by weight. Find out where your part ends up, answer those points from verified supplier data, and treat the rest as contract terms.",
  "theme": {
    "id": "marketplace-retailer",
    "label": "Marketplace and retailer demands"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "RoHS",
    "REACH",
    "GPSR"
  ],
  "path": [
    "product-validation",
    "compliance-status-links"
  ],
  "trigger": "A customer that uses your product as a part, material or component sends a questionnaire before ordering or during a supplier review",
  "keep": null,
  "why": [
    {
      "text": "A business customer that builds your product into its own is usually the manufacturer of the finished product, and it needs your data to meet its duties. Under the RoHS Directive 2011/65/EU, electrical and electronic equipment placed on the market, including cables and spare parts, must not contain the restricted substances above the maximum concentration values per homogeneous material (Article 4(1) and (2)). The manufacturer of the equipment draws up the technical documentation, carries out internal production control under Module A of Decision No 768/2008/EC, draws up the EU declaration of conformity and affixes the CE marking (Article 7(b) and (c)). By drawing up the declaration, it takes responsibility for compliance (Article 13(3)).",
      "sources": [
        1
      ]
    },
    {
      "text": "Component data is what makes that possible. RoHS presumes that materials, components and equipment on which tests and measurements were carried out, or which were assessed, in accordance with harmonised standards comply with the substance limits (Article 16(2)). A supplier that can show such data per part gives the customer evidence it can put in its own file. If you place equipment on the market yourself, the duties fall on you: as manufacturer under Article 7, or as importer under Article 9, which includes keeping a copy of the declaration for 10 years (Article 9(g)).",
      "sources": [
        1
      ]
    },
    {
      "text": "REACH adds a duty that applies whether or not the customer asks. Under Regulation (EC) No 1907/2006, any supplier of an article containing a substance of very high concern identified on the candidate list above 0.1 % weight by weight must provide the recipient with sufficient information, available to it, to allow safe use of the article, including at least the name of the substance (Article 33(1)).",
      "sources": [
        2
      ]
    },
    {
      "text": "Where the finished product goes to consumers, traceability under the General Product Safety Regulation (EU) 2023/988 also reaches back to you: on request, economic operators identify any operator that supplied them with the product or with a part or component, for six years (Article 15(3)(a) and (5)). Authorities can require the same supply chain information (Regulation (EU) 2019/1020, Article 14(4)(b)). Questions beyond these legal points, such as codes of conduct or substance lists that go further than the law, are the customer's own terms.",
      "sources": [
        3,
        4
      ]
    }
  ],
  "steps": [
    {
      "name": "Find out where your product ends up",
      "text": "Ask what the customer makes with your part and where it sells it. A component for electrical equipment brings RoHS data into play; a part of a consumer product brings traceability under the GPSR; a part of an industrial machine brings the machine rules. The questions that matter follow from that."
    },
    {
      "name": "Answer the substance questions from evidence",
      "text": "For RoHS, give the content of the restricted substances per homogeneous material, or a test or declaration based on the harmonised standard. For REACH, state whether the article contains a candidate-list substance above 0.1 % by weight and, if so, which one. Base both on supplier data you can show.",
      "item": "product-validation"
    },
    {
      "name": "Say whether your product is itself in scope",
      "text": "If you place electrical or electronic equipment on the market in your own right, such as a cable, a power supply or a spare part, it needs its own technical documentation, declaration of conformity and CE marking under RoHS. If you supply a material or a part that is not equipment, your data feeds the customer's declaration instead."
    },
    {
      "name": "Separate legal questions from the customer's own",
      "text": "Mark which questions rest on a law that applies to your product and which are the customer's policies, such as codes of conduct, audits or substance lists beyond the law. Answer the second group as far as you can verify; the terms are set by agreement."
    },
    {
      "name": "Keep the answers current",
      "text": "Tie each answer to a product revision and a date. Tell the customer when a material, a supplier or the list of identified substances changes in a way that affects what you declared, and send the updated data.",
      "item": "compliance-status-links"
    }
  ],
  "documents": [
    {
      "name": "Material data per homogeneous material for the restricted substances",
      "from": "Your suppliers, compiled by you",
      "ground": "RoHS Articles 4(2) and 16(2)"
    },
    {
      "name": "Information on candidate-list substances above 0.1 % w/w in the article",
      "from": "Your suppliers, passed on by you",
      "ground": "REACH Article 33(1)"
    },
    {
      "name": "EU declaration of conformity, where you place electrical equipment yourself",
      "from": "You as manufacturer",
      "ground": "RoHS Articles 7(c) and 13"
    },
    {
      "name": "Records of who supplied the part and to whom you supplied it",
      "from": "Your purchase and sales systems",
      "ground": "GPSR Article 15(3)"
    }
  ],
  "risks": [
    {
      "title": "The substance information is owed anyway",
      "text": "Any supplier of an article containing a candidate-list substance above 0.1 % weight by weight must give the recipient sufficient information for safe use, at least the name of the substance (REACH Article 33(1)).",
      "source": 2
    },
    {
      "title": "Your customer cannot declare conformity",
      "text": "The manufacturer of the finished equipment draws up the technical documentation and the EU declaration of conformity and takes responsibility for compliance (RoHS Articles 7(b) and (c) and 13(3)). Without your data it cannot do so for a product containing your part.",
      "source": 1
    },
    {
      "title": "You are named in a traceability request",
      "text": "On request, an economic operator identifies who supplied it with a part or component of the product (GPSR Article 15(3)(a)), and authorities can require supply chain information (Regulation (EU) 2019/1020, Article 14(4)(b)).",
      "source": 3
    }
  ],
  "faq": [
    {
      "q": "Do we need a RoHS declaration of conformity for a component?",
      "a": "Only if you place it on the market as electrical or electronic equipment in its own right; RoHS covers cables and spare parts too (Article 4(1)). For a part built into the customer's equipment, the customer's declaration covers the finished product, and it relies on your material data."
    },
    {
      "q": "What does the 0.1 % rule in REACH mean?",
      "a": "If an article you supply contains a substance of very high concern on the candidate list above 0.1 % weight by weight, you must tell the recipient, giving at least the substance name and the information you have for safe use (REACH Article 33(1))."
    },
    {
      "q": "Is a RoHS test report enough?",
      "a": "Materials and components tested or assessed in accordance with harmonised standards are presumed to comply with the RoHS substance limits (Article 16(2)). A report that names your part and the standard used is therefore strong evidence; a generic report on another part is not."
    },
    {
      "q": "Must we answer questions about substances no law restricts in our product?",
      "a": "No law read for this page requires it. Such questions come from the customer's own policy and are set by agreement. Answer what your supplier data supports, and say so where you do not know."
    }
  ],
  "sources": [
    {
      "title": "Directive 2011/65/EU on the restriction of hazardous substances in electrical and electronic equipment (RoHS), consolidated text of 1 July 2026",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02011L0065-20260701",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EC) No 1907/2006 (REACH), consolidated text of 22 June 2026",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20260622",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "rohs-substances",
    "reach-svhc-question",
    "supplier-material-data",
    "esg-customer-request",
    "retailer-supplier-portal"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-05",
  "notice": "General information, not legal advice."
}