How to prepare a REACH RoHS compliance statement for imported products

What a REACH RoHS compliance statement should answer first

A REACH RoHS compliance statement should tell a buyer, importer or distributor whether a clearly identified product has been assessed against the relevant EU chemical restrictions under REACH and RoHS. A useful statement does more than say “compliant.” It identifies the product, the regulation or substance list checked, the assessment date, the responsible company and the evidence behind the claim.

For importers, the practical issue is not simply whether a supplier can send a certificate. The question is whether the document is specific enough to support customer audits, marketplace reviews, customs or border-related document requests, and EU market surveillance questions. A one-line declaration with no part numbers, dates or substance-list references is weak evidence. A stronger statement belongs in a controlled compliance file that also includes material declarations, supplier confirmations, bills of materials, exemption records and, where appropriate, laboratory reports.

This article explains what to include, how REACH and RoHS differ, and how import teams can review supplier statements before shipment. For related trade compliance topics, visit our Compliance section.

REACH and RoHS are connected but not the same

REACH and RoHS are often requested together because both affect product materials. They are different legal frameworks, however, and treating them as one generic “environmental certificate” is a common mistake.

Under REACH, the European Chemicals Agency describes duties that can arise when an article contains a Substance of Very High Concern on the Candidate List above 0.1% weight by weight. At the time of writing on September 17, 2026, ECHA’s Candidate List shows 253 entries, following the 4 February 2026 update that added two substances. This matters because a statement based on an older list may no longer reflect the current compliance position.

REACH also includes Annex XVII restrictions. These restrictions can apply to certain substances in articles, mixtures or uses, and they are separate from the Candidate List. A supplier statement that only says “SVHC free” does not automatically confirm compliance with all Annex XVII restrictions relevant to the product.

RoHS is narrower in scope but more formal for electrical and electronic equipment. The EU RoHS Directive restricts 10 substance groups in homogeneous materials: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP. Most have a maximum concentration value of 0.1%, while cadmium is limited to 0.01%. For products within scope, RoHS is also linked to technical documentation, conformity assessment, an EU declaration of conformity and CE marking obligations.

What to include in a credible statement

A practical REACH and RoHS statement should be written for a specific product or product family, not for a supplier’s entire factory unless the scope is clearly justified. Importers should ask for enough detail to connect the document to purchase orders, product labels, technical files and customer compliance portals.

At minimum, the statement should include:

• Company identity: legal name, address and contact details of the manufacturer, supplier or authorized issuing party.
• Product identification: model numbers, SKUs, part numbers, product description, revision level and, where possible, product family limits.
• Regulatory scope: a clear statement of whether the document covers EU REACH, EU RoHS, or both.
• REACH basis: Candidate List date or version checked, Article 33 status, Annex XVII review where relevant, and any known SVHC above 0.1% weight by weight.
• RoHS basis: Directive 2011/65/EU, later amendments affecting the restricted substances, applicable exemptions and homogeneous material threshold assumptions.
• Evidence basis: supplier material declarations, bill of materials review, risk assessment, test reports, recognized standards or a combination of these.
• Exceptions: any substances present above thresholds, RoHS exemptions used, parts excluded from the statement, or markets not covered.
• Issue date and validity control: document date, review cycle and a statement that reassessment is needed after material, supplier or regulatory-list changes.
• Authorized signature: name, title and signature or controlled electronic approval from a responsible person.

The wording should avoid absolute promises that cannot be proven. “The product has been assessed against the listed requirements based on supplier declarations and available technical documentation” is usually more defensible than “the product is guaranteed free of all hazardous substances.” A product can contain a regulated substance legally if an exemption applies, if the substance is below the threshold, or if a restriction does not apply to that use.

Evidence matters more than the certificate format

There is no single universal EU form called a combined REACH RoHS compliance statement. Many companies use their own templates, and customers often provide supplier declaration forms. The format is less important than traceability, scope and supporting evidence.

For RoHS, the European Commission has recognized EN IEC 63000:2018 as a harmonized standard for technical documentation used to assess electrical and electronic products with respect to hazardous substance restrictions. In practical terms, this supports a risk-based documentation approach: the manufacturer gathers and evaluates supplier declarations, material information and test reports depending on material risk and supplier reliability.

Laboratory testing can be valuable, but it is not always sufficient by itself. A single finished-product screening may not identify every homogeneous material or every restricted substance risk. Conversely, a paper declaration without material traceability may not withstand an audit. A stronger approach is layered evidence: a controlled bill of materials, component-level supplier declarations, targeted testing for high-risk materials, exemption tracking and change-control records.

For REACH, testing every article against every Candidate List entry is often impractical. Importers usually rely on a combination of supplier material data, substance declarations, targeted test reports for known risk materials and periodic list reviews. If an SVHC is present above 0.1% weight by weight in an article, the statement should not hide that fact. It should identify the substance, explain safe-use information and support downstream communication duties.

Importer review workflow before shipment

Importers should review REACH and RoHS statements before mass production shipment, not after goods arrive. A basic workflow can reduce the risk of rejected deliveries, customer disputes and urgent retesting.

1. Confirm product scope. Decide whether the item is electrical or electronic equipment under RoHS and whether it is an article, mixture or substance under REACH.
2. Map parts and materials. Obtain a bill of materials or at least a high-level component list. Focus on plastics, coatings, solder, cables, batteries, metal finishes, rubber parts, adhesives and pigments.
3. Request current supplier declarations. Ask suppliers to identify the Candidate List date used and whether RoHS exemptions are claimed.
4. Check high-risk materials. Phthalates in soft plastics, lead in solder or alloys, cadmium in pigments or plating, chromium VI in surface treatments and flame retardants in plastics may need closer review.
5. Verify document consistency. Product names, part numbers, revision levels and dates should match purchase records and labels.
6. Escalate gaps before shipment. Missing exemptions, outdated SVHC list references or generic factory-wide statements should trigger clarification.
7. Store the file. Keep declarations, test reports, supplier emails, change notices and review records in a retrievable compliance folder.

This workflow is especially important for traders and distributors that do not design the product. Even when a supplier is responsible for manufacturing, the EU importer or downstream customer may still ask the trading company to provide reliable compliance information. A statement should therefore be treated as a live supply-chain document, not a one-time attachment. See also: Customs.

Common mistakes that weaken a statement

The first common mistake is using an outdated REACH Candidate List. Because ECHA updates the list when new SVHC entries are identified, a declaration issued several years ago may be incomplete even if the product has not changed.

The second mistake is confusing REACH SVHC status with REACH Annex XVII restrictions. A product can have no declarable SVHC above 0.1% and still be affected by a restriction on a specific substance, use or material. Importers should ask suppliers whether the statement covers both Candidate List communication and relevant restrictions.

The third mistake is declaring RoHS compliance without addressing exemptions. Some products lawfully rely on RoHS exemptions for specific uses of restricted substances. If an exemption is used, the statement should name it and track its expiry or review status. A vague “RoHS compliant” claim may become misleading if the exemption has expired or does not apply to the exact application.

The fourth mistake is treating test reports as permanent. Test reports reflect the sample, materials and date tested. If the supplier changes a plasticizer, solder, coating, cable compound or sub-supplier, the previous result may not represent the next shipment. Change control is therefore part of compliance evidence.

The fifth mistake is failing to connect documents to the product sold. A statement that covers “all products manufactured by our company” may be acceptable only if the supplier has a robust controlled system and the relevant product family is clearly included. For most import transactions, product-specific identification is safer.

Sample structure for a REACH and RoHS statement

The following structure can be adapted for supplier requests. It is not legal advice and should be reviewed against the product, market and customer requirements.

• Document title: REACH and RoHS compliance statement.
• Issuer: legal company name, address and responsible department.
• Products covered: model number, SKU, revision, product description and covered accessories.
• REACH statement: “Based on available supplier declarations, material information and product assessment, the products identified above have been reviewed against Regulation (EC) No 1907/2006. The assessment includes Candidate List SVHC communication duties as of [date/list version] and relevant Annex XVII restrictions identified for the product materials and intended use.”
• SVHC disclosure: state either that no Candidate List SVHC is known to be present above 0.1% weight by weight in any article, or list the substance name, article location and safe-use information.
• RoHS statement: “The products identified above have been assessed against Directive 2011/65/EU and applicable amendments for restricted substances in homogeneous materials.”
• RoHS substance status: list the 10 restricted substance groups and confirm whether each is below the maximum concentration value or covered by a stated exemption.
• Evidence basis: supplier declarations, bill of materials review, test reports, EN IEC 63000:2018 technical documentation approach or other controlled evidence.
• Limitations: identify excluded parts, customer-supplied components, packaging, batteries, spare parts or markets outside the statement scope if applicable.
• Approval: name, title, date, signature and document control number.

The statement should also say when it must be reviewed. Good triggers include a change in material, component supplier, manufacturing site, product revision, REACH Candidate List update, RoHS exemption change or customer specification update. Without a review trigger, the document may look current even after the compliance basis has changed.

Frequently asked questions

Is a REACH RoHS compliance statement the same as a test report?

No. A statement is a declaration by the issuer. A test report is evidence from a laboratory for tested samples and substances. A strong compliance file may include both, but one does not automatically replace the other.

Can one statement cover both REACH and RoHS?

Yes, one document can cover both if it clearly separates the REACH and RoHS bases. The statement should not blur the two frameworks because their scope, thresholds, obligations and evidence expectations differ.

How often should importers refresh supplier statements?

At minimum, importers should refresh statements when the product, materials, supplier or regulatory list changes. Many companies also set a routine annual review, with additional checks after ECHA Candidate List updates or RoHS exemption changes.

Does RoHS apply to non-electrical products?

Generally, RoHS applies to electrical and electronic equipment within the directive’s scope. Non-electrical articles may still have REACH obligations, customer substance restrictions, packaging rules or market-specific requirements.

What is the biggest red flag in a supplier declaration?

The biggest red flag is a generic, undated statement with no product identifiers and no reference to the substance list or evidence used. Importers should request clarification before relying on it for shipment or customer approval.