New EU CE and RoHS Compliance Dynamics: Market Access Points for Exporters

For electrical and electronic companies planning to export to the EU, CE marking and RoHS compliance are the two most frequently asked market-access gates. Requirements around the restricted-substance list and conformity documents continue to evolve, so this article outlines the compliance dynamics exporters should watch and how to plan ahead.

The Basic Frame of EU Market Access

Electrical and electronic products entering the EU generally need to satisfy the applicable directives and regulations at the same time. The CE mark is not a single certification; it is the mark applied once a product meets all applicable harmonized legislation (for example the Low Voltage Directive, the EMC Directive and the RoHS Directive). RoHS controls restricted substances in the homogeneous materials of a product and, together with chemical regulations such as REACH, forms the EU compliance system for electrical and electronic products.

Common Changes and Points to Watch

The changes exporters meet most often center on expansion of the restricted-substance list, adjustment of exemptions, and tightening of conformity documents and market-surveillance requirements. RoHS, for example, has enforced mandatory controls on several additional phthalates since 2019, and as technology evolves exemptions are occasionally added or removed. If a product is not re-checked in time, it may run into problems at customs or during market surveillance. [ASSUMED] The specific substance limits and exemption list are those currently published by the EU.

What Exporters Should Do

To cope with continuously changing compliance requirements, exporters are advised to do three things: build a complete bill of materials (BOM) and material declarations so the tested sample matches production; use laboratories holding ISO/IEC 17025 accreditation for compliance testing and keep a complete conformity file; and proactively re-review whenever the product, materials or suppliers change, so that a change does not invalidate a certificate or declaration.

Closing and Consultation

Changes to compliance requirements can affect launch timing and market planning. If you would like to assess an EU CE marking and RoHS compliance program for a specific product, contact the AllTest team for tailored EU market-access advice and a quotation.