RoHS Compliance Declaration

The RoHS Directive has been in force since 2006, with the current version (RoHS 2, 2011/65/EU) extending scope, adding new product categories, and significantly strengthening the obligations on importers and distributors — not just manufacturers. Delegated Directive 2015/863 added four phthalates (DEHP, DBP, BBP, DIBP) to the restricted substances list from 2019, bringing the total to ten. Each substance has its own maximum concentration threshold — 0.1% by weight per homogeneous material for nine substances, and 0.01% for cadmium — and the thresholds apply at the level of individual homogeneous materials within a product rather than to the product as a whole.

The compliance chain begins with component suppliers. Manufacturers must obtain material declarations from every supplier in their Bill of Materials and, where declarations are absent or unverifiable, commission analytical testing — typically XRF (X-ray fluorescence) screening for rapid field triage, followed by ICP-MS (inductively coupled plasma mass spectrometry) for quantitative verification. This upstream evidence forms the basis of the technical file that must accompany the RoHS Declaration of Conformity. The Declaration itself must be kept for ten years after the last product is placed on the market and must be made available to national market surveillance authorities on request.

A widely misunderstood aspect of RoHS is the exemption system in Annexes III and IV. Some uses of restricted substances — certain lead solders in high-reliability applications, for example — are exempt from the thresholds for a defined period. Exemptions have expiry dates and must be periodically renewed by the European Commission; manufacturers relying on an exemption must track its expiry and plan reformulation or seek renewal in advance. Sustalium maintains a live exemption register, cross-referenced to your product declarations, and sends alerts when a relied-upon exemption approaches its review date — preventing the compliance gap that arises when an exemption lapses silently.