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Chemicals and materials Manufacturer · Importer 6 min read

A customer asks for our RoHS declaration

Under the RoHS Directive 2011/65/EU, electrical and electronic equipment must not contain lead, mercury, cadmium, hexavalent chromium, two flame retardant groups or four phthalates above the limits per homogeneous material in Annex II. The manufacturer proves this in its technical documentation and EU declaration of conformity. Collect material data for every part, check the exemptions, then issue or update the declaration and send it.

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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice

Why this happens

The RoHS Directive 2011/65/EU restricts ten substances in electrical and electronic equipment. Member States must ensure that equipment placed on the market, including cables and spare parts for its repair, reuse or upgrading, does not contain the substances listed in Annex II (Article 4(1)). Annex II sets the maximum concentration by weight in homogeneous materials: 0.1 % for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP, and 0.01 % for cadmium.[1]

The limit applies per homogeneous material, not per product (Article 4(2)). A homogeneous material is one material of uniform composition throughout, or a combination that cannot be disjointed by mechanical actions such as unscrewing, cutting, crushing or grinding (Article 3(20)). That is why a customer's question about one product turns into questions about many parts. The applications listed in Annexes III and IV are exempted (Article 4(6)), and many of those exemptions carry their own expiry dates. Directive (EU) 2025/2456 amends the exemption and review provisions in Articles 5 and 6 from 13 August 2027, and the Commission proposed a digital declaration of conformity across several product acts, including RoHS, in COM(2025) 503; the act's EUR-Lex page still lists that as a proposal.[1]

The proof sits with the manufacturer. It must ensure the equipment is designed and manufactured in accordance with Article 4, draw up the technical documentation, carry out internal production control in line with module A of Decision No 768/2008/EC, draw up an EU declaration of conformity and affix the CE marking (Article 7(a) to (c)). The declaration follows the model in Annex VI, is kept up to date and is translated into the languages the Member State requires (Article 13(2)). The file and the declaration are kept for 10 years after the equipment has been placed on the market (Article 7(d)).[1]

Importers and distributors have their own checks. An importer ensures that the manufacturer carried out the conformity assessment, drew up the technical documentation and affixed the CE marking, and keeps a copy of the declaration for 10 years (Article 9(b) and (g)). A distributor verifies the CE marking and the accompanying documents (Article 10(a)). Equipment bearing the CE marking is presumed to comply in the absence of evidence to the contrary (Article 16(1)).[1]

RoHS is not the only chemical question a customer may ask. The directive applies without prejudice to Union chemicals legislation, in particular REACH (Article 2(3)). Questions about substances of very high concern in articles fall under Article 33 of Regulation (EC) No 1907/2006.[1][2]

How to solve it

  1. Confirm the product is in scope

    RoHS applies to electrical and electronic equipment in the categories of Annex I, including cables and spare parts. Check the exclusions in Article 2(4), such as large-scale fixed installations or means of transport, before you answer that a product is covered or not.

  2. Collect data per homogeneous material

    The limits apply to each homogeneous material, not to the whole product: a solder joint, a cable sheath, a plastic housing, a coating. Ask your suppliers for material declarations or test results per part, and check them against the ten substances and limits in Annex II.

  3. Check every exemption you rely on

    Some uses are exempted in Annex III, such as certain uses of mercury in lamps, and in Annex IV for medical devices and monitoring and control instruments. Many exemptions carry an expiry date. Write down which exemption numbers you use and when each one expires, so the declaration stays true.

  4. Draw up the file and the declaration

    The manufacturer draws up the technical documentation under internal production control (module A), then an EU declaration of conformity with the elements in Annex VI and the CE marking. Where the product also needs a declaration under other acts, one technical file may cover them.

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  5. Send it and keep it current

    Give the customer the declaration for the exact model. Keep it, with the file, for 10 years. When you change a component, a supplier or an exemption expires, review the data and update the declaration, as the directive requires changes in design to be taken into account.

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What you need to show

DocumentWhere it comes fromLegal ground
EU declaration of conformity with the Annex VI elementsThe manufacturerDirective 2011/65/EU Article 7(c), Article 13 and Annex VI
Technical documentation under module A, with material data per homogeneous materialThe manufacturer, with data from suppliersDirective 2011/65/EU Article 7(b) and Article 4(2)
List of exemptions used, with expiry datesThe manufacturerDirective 2011/65/EU Article 4(6) and Annexes III and IV

If you do nothing

Equipment above the limits may not be placed on the market

Member States must ensure that equipment placed on the market does not contain the substances in Annex II above the maximum concentration values per homogeneous material (Directive 2011/65/EU Article 4(1) and (2)).[1]

Corrective action and information to authorities

A manufacturer who has reason to believe that equipment is not in conformity must immediately take corrective measures, withdraw or recall it if appropriate, and inform the competent national authorities (Directive 2011/65/EU Article 7(i)).[1]

An importer must stop before placing it

Where an importer has reason to believe that equipment does not conform with Article 4, it must not place it on the market until it has been brought into conformity, and must inform the manufacturer and the market surveillance authorities (Directive 2011/65/EU Article 9(c)).[1]

Questions about this problem

Is there such a thing as a RoHS certificate?

Not as a legal document. The directive uses internal production control, module A, and the manufacturer issues the EU declaration of conformity itself (Directive 2011/65/EU Article 7(b) and (c)). A test report can support the file, but it does not replace the declaration.

Do we need a separate RoHS declaration next to our CE declaration?

Not necessarily. The RoHS declaration must contain the elements in Annex VI (Article 13(2)). Where other acts apply, a single technical documentation may be drawn up (Articles 7(c) and 13(2)). The directive does not say whether the RoHS declaration may be combined with declarations under other acts; check the rules of those acts.

Which phthalates are restricted?

DEHP, BBP, DBP and DIBP, each at 0.1 % by weight in homogeneous materials (Directive 2011/65/EU Annex II). The RoHS restriction of DEHP, BBP and DBP does not apply to toys already covered by entry 51 of REACH Annex XVII (Annex II); DIBP stays restricted under RoHS in electrical toys, and entry 51 covers all four in toys.

What is a homogeneous material?

One material of uniform composition throughout, or a combination of materials that cannot be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes (Directive 2011/65/EU Article 3(20)).

Does RoHS compliance cover REACH as well?

No. RoHS applies without prejudice to REACH (Directive 2011/65/EU Article 2(3)). A customer can also ask about substances of very high concern under Article 33 of Regulation (EC) No 1907/2006, which is a separate check.

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Regulations involved

REACHRoHS

Sources

  1. Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (consolidated text of 1 July 2026) EUR-Lex · accessed 4 October 2026
  2. Regulation (EC) No 1907/2006 (REACH) (consolidated text of 22 June 2026) EUR-Lex · accessed 4 October 2026

About this page

Reviewer
Conphora compliance team
Reviewed
4 October 2026

General information, not legal advice. Check the legal text or ask an adviser about your own product.

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Cite this page 
Conphora (2026). A customer asks for our RoHS declaration. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/rohs-substances/
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