What RoHS compliance means
RoHS stands for Restriction of Hazardous Substances. In the EU it is Directive 2011/65/EU, often called RoHS 2, as amended by Delegated Directive (EU) 2015/863. It limits ten substances in electrical and electronic equipment (EEE): lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates (DEHP, BBP, DBP and DIBP). Limits apply in each homogeneous material, meaning each individual plastic, solder, coating or metal part, not the product as a whole.
Great Britain applies its own RoHS Regulations 2012 (as amended), and products placed on the GB market can carry the UKCA marking. Other markets, including India under its e-waste rules, have similar hazardous substance limits.
There is no government-issued "RoHS certificate". The manufacturer, or the importer for goods made outside the EU, keeps technical documentation, draws up an EU Declaration of Conformity and affixes the CE marking. Lab test reports and third-party audits are evidence you use to support that declaration. BookMyLLC helps you build that evidence and paperwork.
Who this is for
- Manufacturers in India, China, Southeast Asia or elsewhere exporting electronics or electrical goods to the EU or UK.
- Brand owners and Amazon or marketplace sellers importing finished products into the EU or UK.
- Component suppliers asked by customers for RoHS declarations and material data.
- Hardware startups preparing a first production run.
RoHS covers a wide range of EEE, from cables and chargers to appliances, lighting, IT equipment and toys with electronics. Some categories are excluded or carry time-limited exemptions, so the first step is confirming whether and how your product is covered.
What BookMyLLC handles
- Scope check: whether the product is EEE under the directive and which category it falls in.
- A bill of materials review to find the homogeneous materials that carry the most risk.
- Supplier declaration requests and review, including material data and test reports from component suppliers.
- Coordination with testing laboratories where declarations are missing or unreliable, for example XRF screening followed by chemical testing.
- Assessment of any exemptions you rely on and their expiry dates.
- The technical file and the EU or UK Declaration of Conformity drafted for your signature.
- Guidance on CE or UKCA marking placement and labelling.
- A process for re-checking compliance when components or suppliers change.
Step-by-step process
- Product intake. You share the product, its markets and the bill of materials.
- Risk ranking. Parts such as PVC cables, solder, coatings and imported sub-assemblies are ranked by likelihood of restricted substances.
- Supplier evidence. We collect and check declarations and reports against the ten substances.
- Testing where needed. Gaps are closed with laboratory testing of the relevant materials.
- Technical documentation. Evidence is compiled into a file that a market surveillance authority can review.
- Declaration and marking. You sign the Declaration of Conformity as manufacturer or importer and apply the marking.
- Change control. A simple procedure triggers a review when a supplier or material changes.
Documents and information you need
- Product description, model numbers, photos and intended markets.
- Bill of materials with supplier names and part numbers.
- Existing supplier RoHS or REACH declarations and any lab reports.
- Details of the legal manufacturer and the EU or UK importer.
- Other directives the product falls under, such as low voltage or EMC, since the CE marking covers all of them.
Timeline
If suppliers have reliable declarations, documentation for a simple product is typically ready in a few weeks. Products with many components, weak supplier data or required lab testing usually take longer, often driven by lab turnaround and supplier response times. Documentation must be kept for ten years after the last unit is placed on the market.
Common mistakes to avoid
- Testing the finished product only. Limits apply to each homogeneous material, so a whole-product result can hide a failing part.
- Accepting a generic supplier letter. Declarations should name the part and be backed by data.
- Forgetting the phthalates. DEHP, BBP, DBP and DIBP were added in 2015 and are common in cables and soft plastics.
- Relying on an expired exemption. Many exemptions have end dates.
- Confusing RoHS with REACH. They are separate EU laws with different substance lists and duties.
This page is general guidance, not legal advice. For your product's obligations, confirm with a product compliance specialist or lawyer in the target market.
Who is responsible when you sell from outside the EU
If your company is in India, China or the US and you sell into the EU, someone inside the EU takes on legal duties. When goods are imported, the importer must check that the manufacturer has carried out conformity assessment, that the CE marking and documentation are present, and that the importer's own name and address appear on the product or packaging. Fulfilment services and marketplaces also face obligations under EU market surveillance rules, which is why many ask sellers for a Declaration of Conformity before listing.
In practice, this means your EU importer or authorised representative will ask you for the technical file. Having it ready, in English and organized by component, makes that relationship much easier and reduces the chance of goods being held at customs or delisted.
Keeping compliance current
RoHS compliance is not a one-time exercise. Exemptions are reviewed and some expire, suppliers change materials without notice, and the substance list can be amended. A light annual review of supplier declarations for your highest-risk parts, plus a trigger for any design or supplier change, keeps your declaration accurate.
Related services
RoHS is usually one part of a CE marking project, so see our CE mark certification service. Exporters often also need ISO 9001 quality management or ISO 14001 environmental management. For fees, see current pricing or book a call.
RoHS at a glance
| Question | Short answer |
|---|---|
| What it limits | Hazardous substances such as lead, mercury and cadmium in electrical and electronic products. |
| Evidence | Supplier declarations, test reports and a technical file. |
| Who is responsible | The manufacturer or importer who places the product on the market. |
| Records | Kept for ten years after the last unit is sold. |
| Typical effort | A few weeks for simple products. |
Evidence you will need
| Item | Why |
|---|---|
| Bill of materials | Lists every component |
| Supplier declarations | Show substance limits are met |
| Test reports | Cover items with weak supplier data |
| Technical file | Brings the evidence together |
| Declaration of conformity | Signed by the responsible person |
Products with many components or weak supplier data take longer. See CE marking if you are also selling into Europe.
Responsibilities when you sell from outside the market
If you make products abroad and sell into a market that applies RoHS, the importer or the manufacturer's representative usually shares responsibility for compliance. Marketplaces and distributors increasingly ask for a declaration of conformity and test evidence before they list a product, so it is worth having them ready before you apply.
Compliance is not a one-off. A new supplier, a changed component or a revised rule can change your position, so we recommend a review whenever the bill of materials changes.
Typical product types we handle
- Consumer electronics and accessories.
- LED lighting and power supplies.
- Industrial control and measurement equipment.
- Cables, connectors and batteries, subject to their own rules.
