RoHS Compliance for Electronics Importers: What the Paperwork Actually Means

Every electronics supplier in China will hand you a RoHS declaration. Most of those declarations aren’t worth the paper they’re printed on.

That’s not necessarily fraud, often it’s just how the industry works. A supplier fills out a self-declaration template, signs it, and sends it along with your order. No testing happened. No lab measured the actual substances in the materials. The supplier is guessing, or trusting their upstream component suppliers, or just telling you what you want to hear.

For most importers, the gap between what RoHS paperwork looks like and what it actually proves is the single biggest compliance blind spot in the sourcing process.

What RoHS Actually Restricts

RoHS stands for Restriction of Hazardous Substances. The EU directive (2011/65/EU, often called RoHS 2) restricts specific hazardous substances in electrical and electronic equipment placed on the EU market.

The original six substances from the first directive (2002/95/EC) are:

Lead (Pb). Mercury (Hg). Cadmium (Cd). Hexavalent chromium (Cr VI). Polybrominated biphenyls (PBB). Polybrominated diphenyl ethers (PBDE).

RoHS 3 (Directive 2015/863/EU, effective July 2019) added four phthalates: DEHP, BBP, DBP, and DIBP. These are plasticizers used in PVC cables, insulation, and plastic components. Their addition expanded the testing burden considerably for products with significant plastic content.

So the current restricted list has 10 substances total. A “RoHS compliant” product must fall below the maximum concentration values for all 10.

Maximum Concentration Values

The limits matter. RoHS doesn’t require zero presence of these substances, it requires that concentrations stay below defined thresholds in homogeneous materials.

“Homogeneous material” means a material that can’t be mechanically separated into different materials. A coated wire has multiple homogeneous materials: the copper core, the insulation layer, and any outer jacket. Each is measured separately.

The concentration limits:

Lead: 0.1% by weight (1,000 ppm). Mercury: 0.1% by weight (1,000 ppm). Cadmium: 0.01% by weight (100 ppm). Hexavalent chromium: 0.1% by weight (1,000 ppm). PBB: 0.1% by weight (1,000 ppm). PBDE: 0.1% by weight (1,000 ppm). DEHP: 0.1% by weight (1,000 ppm). BBP: 0.1% by weight (1,000 ppm). DBP: 0.1% by weight (1,000 ppm). DIBP: 0.1% by weight (1,000 ppm).

Cadmium has a much tighter limit than the others, 10 times stricter. It shows up in certain types of rechargeable batteries and some pigments.

Which Products RoHS Covers

RoHS applies to electrical and electronic equipment (EEE) placed on the EU market. The directive defines ten categories:

Large household appliances. Small household appliances. IT and telecommunications equipment. Consumer equipment. Lighting equipment. Electrical and electronic tools. Toys, leisure, and sports equipment. Medical devices. Monitoring and control instruments. Automatic dispensers.

Since 2019, the directive also applies to all other EEE not covered by the above categories, making the scope effectively unlimited for practical purposes.

If you’re importing electronics for the EU market, assume RoHS applies unless you have specific reason to believe otherwise. The exemptions (covered below) are narrow.

RoHS vs. REACH: How They Overlap

Importers often confuse RoHS and REACH, or assume complying with one covers the other.

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a broader EU chemical regulation. It restricts substances of very high concern (SVHCs) across all product types, not just electronics. The SVHC candidate list has over 230 substances at this point, updated twice yearly.

RoHS and REACH overlap on some substances but address different scopes. REACH covers more substances but applies based on material content across all products. RoHS covers fewer substances but applies specifically to electronics with stricter concentration limits for those substances.

Complying with RoHS doesn’t mean you’ve satisfied REACH. A product with compliant RoHS substance levels might still contain REACH SVHCs above threshold concentrations.

For electronics importers, the practical answer is to request both RoHS and REACH documentation from suppliers. They’re separate compliance requirements and need separate documentation.

The Difference Between a Declaration and a Test Report

This is the most important thing in this article.

A RoHS declaration is a document where a supplier (or component supplier) states that their product meets RoHS requirements. It’s a promise. No lab measured anything. The person signing it is asserting compliance based on their knowledge of the materials used, which may or may not be accurate.

A RoHS test report is a document from an accredited laboratory showing actual measured concentrations of restricted substances in specific materials from your actual product. XRF screening (X-ray fluorescence) can identify likely problem substances quickly and cheaply. Full wet chemical analysis (following IEC 62321 standards) provides definitive concentration measurements by homogeneous material.

Both types of documents look similar to the untrained eye. Both have logos, signatures, and the word “RoHS” on them. But they prove completely different things.

For low-risk products where you have a strong, verified supply chain relationship and the product uses well-established materials with clear provenance, supplier declarations may be an acceptable starting point. For products with complex material compositions, significant plastic content, solders, surface coatings, or new supplier relationships, you should have actual test reports.

The EU’s IEC 62321 standard series defines the correct testing methods for each restricted substance. Any test report you accept should reference these methods. A report that doesn’t cite specific test methods for each substance is incomplete.

RoHS Exemptions: Narrow and Product-Specific

RoHS does allow some exemptions. They’re listed in Annexes III and IV of the directive and are periodically reviewed.

Common exemptions include: lead in high-melting-point solder (above 85% lead), lead in compliant pin connector systems, lead in solders for servers and storage and storage array systems, mercury in certain fluorescent lamps, and others.

Exemptions are time-limited. The EU reviews them every 5 years to determine whether alternatives exist. When an exemption expires without renewal, products relying on it must either switch to compliant materials or exit the EU market.

If your product relies on a RoHS exemption, document which exemption applies and its current validity period. Don’t assume exemptions are permanent.

US RoHS: California’s Version

The US has no federal RoHS equivalent. However, California passed its own Electronic Waste Recycling Act (SB 20), which restricts some of the same substances in covered electronic devices sold in California.

California’s restriction list is narrower than EU RoHS, it covers lead, mercury, cadmium, and hexavalent chromium, but not the phthalates or PBB/PBDE. The covered products are also narrower: primarily monitors, televisions, and portable computers.

If you sell electronics nationally in the US, California’s rules technically apply to sales in that state. In practice, most companies selling EU-RoHS-compliant products are automatically compliant with California’s version, since EU limits are at least as strict.

Other US states have considered RoHS-type legislation but haven’t enacted comprehensive restrictions as of early 2026. Federal legislation has been proposed but not passed.

China RoHS: A Separate Requirement

China has its own hazardous substance restriction regulation, commonly called China RoHS. The current version is based on GB/T 26572 (the mandatory standard) and its companion requirements under Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products.

China RoHS covers the same six original substances as EU RoHS and uses similar concentration limits. But China RoHS has a different compliance mechanism. Products in certain categories must complete a conformity assessment and either self-declare or obtain third-party certification before they can be sold in China. Many categories require marking with a hazardous substance disclosure table on the product or packaging.

The China RoHS restricted substance table must identify which substances are present above threshold in which components. This disclosure is mandatory, not optional. If you’re selling electronics in China, either directly or through Chinese distribution, factor in China RoHS requirements separately from EU RoHS. They share a philosophy but have different compliance procedures.

What to Request from Your Supplier

When you’re sourcing electronics and need RoHS documentation, here’s the minimum you should ask for.

A full material disclosure (FMD) or material declaration: a detailed list of materials and components in the product, with substance concentrations for the 10 restricted substances by homogeneous material. IPC-1752A XML format is the industry standard for this.

IEC 62321-compliant test reports: actual laboratory measurements for at minimum the substances most likely to be problematic given the product’s construction. For a product with solder joints, lead testing is mandatory. For a product with significant PVC content, phthalate testing matters.

Component-level declarations from the supply chain: RoHS compliance is only as strong as the components used. A supplier who can show you RoHS declarations from their component suppliers (capacitors, connectors, cables, plastic parts) is giving you more confidence than one who only provides a product-level declaration.

A REACH compliance statement: separate from RoHS, as discussed above.

Red Flags in Supplier RoHS Paperwork

Watch for these warning signs.

A one-page declaration with no substance-specific data. Real compliance documentation lists concentrations by substance and by material. A generic declaration that just says “this product complies with RoHS” provides no evidence.

Test reports without IEC 62321 method references. Legitimate RoHS test reports cite the specific test method used for each substance. If you see results without method citations, the report is incomplete at best.

Test reports from labs you can’t verify. Check the lab’s accreditation independently. Search for the lab’s ISO 17025 accreditation certificate from a recognized national body. If you can’t verify the lab exists and is accredited, don’t trust the report.

Reports that only cover the original six substances and ignore phthalates. Since July 2019, the four phthalates are required. Any report that doesn’t address all 10 substances is incomplete for EU RoHS 3 compliance.

Declarations that are dated years before your product samples. RoHS compliance is material-specific. If the supplier changed components since the last test, the old test report doesn’t cover the current product. Ask when the product was last tested and whether any components have changed since then.

Practical Steps for Your Next Sourcing Order

Before you commit to a supplier for EU-destined electronics: ask for their full RoHS documentation upfront, not after the first order. Evaluate whether they provide actual test reports or only declarations.

For first orders with a new supplier, consider third-party XRF screening of your product samples before the full production run. XRF can screen for lead, cadmium, mercury, chromium, and bromine (as a proxy for PBB/PBDE) quickly and inexpensively, typically $200-500 per product depending on complexity. It won’t detect phthalates (those require chemical analysis) but it’ll catch the most common failures.

For products with significant plastic content or new PVC cables, full IEC 62321-compliant chemical testing for phthalates costs $400-800 per material type. Worth doing before a large order if you have any doubt about the supply chain.

Build RoHS documentation requirements into your purchase contracts. Specify that the supplier must provide updated test reports if any materials or components change. Get it in writing before you place the order, not after.

Frequently Asked Questions

Is a RoHS declaration the same as a RoHS test report? No. A declaration is a supplier’s written statement that they believe the product is compliant. A test report is a laboratory document showing actual measured substance concentrations by material. Declarations don’t require any testing. Test reports do. Both documents look similar on paper, but only test reports provide actual measurement data.

Does RoHS apply to products I sell only to businesses, not consumers? Yes. RoHS applies to electrical and electronic equipment placed on the EU market regardless of whether the buyer is a business or a consumer. B2B transactions don’t create an exemption.

What’s the difference between EU RoHS and China RoHS? They restrict similar substances at similar concentration limits, but compliance procedures differ. EU RoHS is self-declaration with technical file documentation. China RoHS requires specific conformity assessment procedures and mandatory hazardous substance disclosure tables on the product or packaging. Separate compliance processes are required for each market.

How often do I need to retest a product for RoHS compliance? There’s no mandatory retesting interval, but you must have current evidence of compliance. If a supplier changes any materials or components, your existing test reports may no longer cover the current product. Build notification requirements into supplier contracts so you know when changes happen.

Do US importers need to worry about RoHS? Unless you’re selling in California (which has a narrower restriction applying to specific product categories) or exporting to the EU, federal US law doesn’t require RoHS compliance. But many US retailers and B2B buyers now contractually require RoHS compliance regardless of legal obligation, so having the documentation matters for commercial reasons even where there’s no legal requirement.

What does “homogeneous material” mean for RoHS testing? A homogeneous material is one that can’t be mechanically separated into different materials. RoHS concentration limits apply per homogeneous material, not per whole product. A wire, for example, has at least two homogeneous materials: the conductor and the insulation. Each is measured separately against the concentration limits.