Entering the EU Market: Restriction of Hazardous Substances (RoHS)

The RoHS Directive restricts the use of ten hazardous substances in electrical and electronic equipment. The limits are based on homogeneous material — calculated not over the product as a whole but over each separable material.

The obligation lies with the manufacturer and no notified body is provided for; conformity assessment is carried out through internal production control. RoHS is also listed separately in the EU Declaration of Conformity.

• The bill of materials (BOM) and the homogeneous-material breakdown
• Supplier RoHS declarations of conformity and material declarations
• Analysis reports for critical materials
• The list of exemptions relied on and their justification
• Technical documentation under EN IEC 63000

1. 01Scope DeterminationIt is determined which legislation and marking scope the product falls under in the target market. This step defines the entire process; getting it wrong wastes all subsequent work.
2. 02Determining Applicable StandardsThe standards accepted by the market and any national deviations are identified. The same IEC standard may apply with different deviations in different markets.
3. 03Establishing the Test PlanIt is assessed which part of existing test reports will be accepted; missing tests are planned. A CB Scheme report, if available, reduces retesting.
4. 04Local Party and RegistrationIf the market requires an established representative, importer or applicant, this party is designated and the necessary registrations are made.
5. 05Tests and Technical FileTests are conducted and the technical file is prepared. Some markets require testing to be performed within their own country.
6. 06Certification or DeclarationDepending on the market's regime, a manufacturer's declaration is drawn up or a certificate is obtained from the authorised body; a factory audit is carried out if required.
7. 07Marking and LabellingThe mark and label are applied according to the market's format and language rules. The language requirement is checked at customs in most markets.
8. 08Shipment and CustomsIf a pre-shipment document is required, it is obtained; the document set to be presented at customs is completed.

• The limits are based on homogeneous material; proportioning them to the product's weight is incorrect
• Because exemptions are time-limited, they must be monitored regularly
• A supplier declaration is accepted but the reliability of that declaration is the manufacturer's responsibility
• China RoHS and other countries' regimes must be assessed separately

1. 01RoHS and REACHRoHS limits certain substances in electrical products by threshold; REACH is an arrangement for substance registration, authorisation and restriction and extends to all products. The two apply together and neither satisfies the other.
2. 02RoHS and waste legislationWaste electrical equipment legislation creates collection and recovery obligations; RoHS governs the content of the product. The two are two different ends of the same problem.
3. 03RoHS and packaging legislationHeavy metal limits in packaging come from separate legislation; a product's RoHS conformity does not cover its packaging.
4. 04RoHS and similar arrangements in other marketsMany markets have introduced similar restrictions, but the scope, thresholds and exemption lists are not the same; EU conformity cannot be transferred directly.

This page describes entry into the European Union market. The scheme itself — its scope, process, validity period and required documents — is covered in detail on the certification page.

This section's content is being prepared. The roadmap specific to your product and target market at the quote stage in writing.