The Complete Guide to EU RoHS Certification: Restricted Substances, Testing and Compliance

EU RoHS (Restriction of Hazardous Substances) is the core compliance requirement controlling hazardous substances in electrical and electronic equipment placed on the EU market. It requires EEE to meet the substance limits of Directive 2011/65/EU and to achieve legal circulation through an EU Declaration of Conformity (DoC) and the CE mark.

Background and Definition

The RoHS Directive restricts the use of certain hazardous substances in electrical and electronic equipment. The EU published the first version (2002/95/EC) in 2002 and then reissued it as 2011/65/EU (recast) in 2011, replacing the original, with each member state transposing it into national law. The core goal is to reduce the environmental and health risks of EEE during use and at end-of-life recycling.

Regulatory Basis

The regulatory basis for RoHS is EU Directive 2011/65/EU. The later amendment (EU) 2015/863 expanded the restricted substances from 6 to 10, enforceable from 22 July 2019. Its Annex II lists the 10 restricted substances:

• Lead (Pb)
• Mercury (Hg)
• Cadmium (Cd)
• Hexavalent chromium (Cr(VI))
• Polybrominated biphenyls (PBB)
• Polybrominated diphenyl ethers (PBDE)
• Bis(2-ethylhexyl) phthalate (DEHP)
• Butyl benzyl phthalate (BBP)
• Dibutyl phthalate (DBP)
• Diisobutyl phthalate (DIBP)

For the limits: cadmium (Cd) is limited to 0.01% (100 ppm), while all other substances are limited to 0.1% (1000 ppm), expressed as a percentage of the homogeneous material by mass.

Scope and Product Categories

Annex I sets out the categories of EEE covered by RoHS: household appliances, IT and telecommunications equipment, consumer electronics, lighting, power tools, toys and leisure equipment, medical devices, monitoring and control instruments, automatic dispensers, and other EEE. Whether a specific product falls within scope depends on its function and the applicable exemption list, because exemptions change as technology evolves.

Core Test Items

RoHS compliance testing focuses on the 10 restricted substances above. Laboratories typically begin with XRF (X-ray fluorescence) screening, then perform quantitative wet chemistry analysis (ICP-OES, ICP-MS, IP-AES and similar) on any homogeneous material flagged as potentially non-compliant. When sending a complete unit or components, ensure the sample materials match production (as documented in the BOM and material declarations). Testing laboratories generally should hold ISO/IEC 17025 accreditation.

Certification Process

RoHS is not a one-time certificate model; it is a compliance route centered on the Declaration of Conformity (DoC). A typical workflow is as follows, subject to the product category and laboratory schedule:

1. Confirm the product and applicable directives
2. Prepare the bill of materials (BOM) and material declarations
3. XRF screening
4. Wet chemistry quantitative testing
5. Consolidate test reports and conformity documents
6. Issue the EU Declaration of Conformity (DoC)
7. Affix the CE mark

Required Documents

[ASSUMED] The exact documentation depends on the laboratory and certification body requirements. Common materials include:

• Bill of materials (BOM)
• Material declarations for each part
• Component specifications and material data
• Product and packaging descriptions
• Any existing test reports

Cost and Certification Cycle

[ASSUMED] RoHS testing cost and lead time vary with the product category, the number of homogeneous materials and the sample size, typically around 2 to 6 weeks and ranging from a few thousand to tens of thousands of yuan. The figures above are a general industry range. For an exact quotation, contact AllTest, and always use phrasing such as “about” or “depends on the product”.

Common Questions and Notes

• EU RoHS vs China RoHS: China RoHS (GB/T 26572) differs from EU RoHS in the controlled substances, marking and scope, so exporters should assess both.
• Exemptions: Certain applications (for example lead in high-temperature solder) are exempt, and should be confirmed per product.
• Overlap with REACH: RoHS controls restricted substances inside products, while REACH covers chemicals across the supply chain; both are often considered together.
• Relationship to the CE mark: RoHS is one of the conformity requirements within the CE framework. EEE entering the EU must also satisfy the other applicable directives (for example LVD and EMC).

Post-Certification Maintenance

RoHS has no periodic mandatory re-certification, but any change to materials, suppliers or structure can alter the compliance status. A BOM change typically triggers retesting and a DoC update. In addition, EU market surveillance authorities may conduct sampling, so keep a complete conformity file for inspection.

Closing and Consultation

This guide covers the background, regulatory basis, scope, testing, process and maintenance of EU RoHS certification. For a tailored certification plan, quotation and lead time, contact the AllTest team for export compliance advice specific to your product.

Certification Quick Facts

Applicable regulation

EU RoHS Directive 2011/65/EU (amended by (EU) 2015/863)

Applicable products

Electrical and electronic equipment (EEE)

Certification cycle

About 2 to 6 weeks, depending on product category and laboratory schedule

Certificate validity

No mandatory re-certification; material or structural changes require re-review

Core test items

10 restricted substances plus 4 phthalates

Certification Process

1. 1

   Initial review and document pre-check

   Confirm the product category and applicable directives, then prepare the bill of materials (BOM) and material declarations

2. 2

   XRF screening

   Run X-ray fluorescence (XRF) screening on samples to flag potentially non-compliant materials

3. 3

   Wet chemistry testing

   Quantify the flagged materials using ICP-OES, ICP-MS or similar methods

4. 4

   Document review

   Compile and submit the test reports, BOM and material declarations

5. 5

   Issue the EU Declaration of Conformity (DoC)

   Issue the DoC based on the applicable directives as the basis for the CE mark

6. 6

   Affix the CE mark

   Affix the CE mark and keep the compliance file ready for market surveillance