How to prepare a RoHS and REACH compliance declaration for EU trade

What the declaration should prove

A RoHS and REACH compliance declaration is a supplier statement confirming that a product, component, material, or defined product family has been checked against EU hazardous-substance requirements. For trade use, it should do more than state that the item is compliant. It should identify the product scope, name the legal references used, state the substance list or regulation version checked, disclose exemptions or substances of very high concern where relevant, and point to the evidence behind the claim.

RoHS applies mainly to electrical and electronic equipment within its scope and sets maximum concentration limits in homogeneous materials. REACH is broader. It can affect substances, mixtures, and articles, including non-electrical products. A combined declaration can be useful for importers, exporters, distributors, and procurement teams, but only if the RoHS and REACH conclusions remain separate.

The regulatory basis for this article includes the European Commission’s RoHS information, the EUR-Lex consolidated text of Directive 2011/65/EU, ECHA guidance on Candidate List substances and SCIP, and European Commission guidance on CE marking and declarations of conformity.

For more trade compliance topics, see the Dumbopus Compliance section.

RoHS and REACH are different compliance questions

Many supplier forms cover RoHS and REACH in one document, but the two regimes are not asking the same thing. Treating them as a single environmental compliance statement is a common weakness in import files.

RoHS is product-scope driven. It applies to electrical and electronic equipment within the scope of Directive 2011/65/EU and restricts listed substances in each homogeneous material. A homogeneous material is a material of uniform composition that cannot be mechanically separated into different materials. In practice, a cable jacket, solder joint, plating layer, plastic housing, and printed circuit board laminate may each need separate assessment.

The consolidated EUR-Lex text of the RoHS Directive dated 1 July 2026 lists ten restricted substances in Annex II. Lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP are restricted at 0.1% by weight in homogeneous materials. Cadmium is restricted at 0.01% by weight. RoHS also contains exemptions in Annexes III and IV. These exemptions can be category-specific, use-specific, and time-limited. A credible declaration should not hide behind the word compliant if compliance depends on an exemption.

REACH is substance and supply-chain driven. Regulation (EC) No 1907/2006 covers registration, evaluation, authorisation, and restriction of chemicals. For finished goods, two REACH areas commonly appear in declarations: Candidate List substances of very high concern, often called SVHCs, and Annex XVII restrictions. ECHA updates the Candidate List over time, so a declaration should state the Candidate List date used for the assessment rather than relying on an undated sentence.

REACH Article 33 requires suppliers of articles containing a Candidate List SVHC above 0.1% weight by weight to provide enough information for safe use to business recipients and, on request, to consumers. ECHA guidance also treats complex products as assemblies of articles, so the 0.1% question should be considered at the article or component-article level, not only against the total weight of the finished product. Since 5 January 2021, suppliers placing articles on the EU market with Candidate List SVHCs above 0.1% also face SCIP notification duties under the Waste Framework Directive framework.

What to include in a combined declaration

A useful combined document should read like a controlled compliance record, not a marketing claim. Importers need to see what was assessed, who is responsible for the statement, and where the limits of the statement are.

Where the product is subject to CE marking rules, the RoHS conclusion may be part of the EU Declaration of Conformity for the finished electrical or electronic product. In that case, the manufacturer is normally responsible for conformity assessment, technical documentation, the EU declaration, and CE marking. A material compliance declaration from a supplier can support that file, but it is not the same as the final EU Declaration of Conformity for a product placed on the EU market.

Evidence that should sit behind the declaration

A declaration is only as strong as the evidence behind it. For RoHS, that evidence normally starts with the bill of materials and supplier material data. Risk is not evenly distributed across a product. Solder, plating, pigments, PVC cable insulation, flame-retarded plastics, rubber parts, adhesives, and legacy components often need closer review than simple metal parts with known material grades.

Testing can help, but it should not be treated as the whole compliance file. XRF screening may identify certain elements such as lead, cadmium, mercury, chromium, and bromine, but it may not distinguish all chemical forms or confirm every organic restricted substance. More specific laboratory methods may be needed where screening results are uncertain or where the material risk is high. EN IEC 63000:2018 is commonly used as the harmonised standard for technical documentation supporting RoHS assessment of electrical and electronic products. IEC 62321 test methods may also be referenced when laboratory testing is part of the evidence package.

For REACH, the evidence often depends more on supply-chain chemical disclosure than on a single finished-product test. A broad test report stating that no SVHC was detected may be useful, but it can become outdated when the Candidate List changes. Better practice is to combine supplier declarations, material declarations, safety data sheets for substances and mixtures, article-level SVHC review, and a process for checking Candidate List updates.

Full material declarations are usually stronger than simple yes-or-no supplier letters because they allow importers to evaluate new restrictions without asking the whole supply chain again. However, many suppliers cannot provide full formulations for intellectual property reasons. In that case, the importer should keep a documented risk assessment showing which materials were reviewed, which supplier statements were received, which tests were used, and which assumptions were made.

Common trade risks when declarations are too broad

The first risk is an undated REACH statement. A sentence such as products comply with REACH is too vague for most serious compliance files. REACH contains many obligations, and Candidate List duties depend on the list in force when the article is supplied. The declaration should say whether the product was assessed against the Candidate List as of a specific date and whether any SVHC is present above 0.1% w/w in any article.

The second risk is using total product weight for RoHS. RoHS limits apply by homogeneous material. A small plating layer or solder joint can exceed a limit even if the finished product average appears low. Importers should reject declarations that only say the finished product is below 0.1% without explaining the material-level basis.

The third risk is ignoring exemptions. RoHS exemptions are legal tools for specific uses, but they are not the same as absence of restricted substances. If lead is present in a solder application covered by an exemption, the declaration should state the exemption rather than imply that no lead is present. This distinction matters when customers phase out exemptions, when product categories change, or when an exemption expires. See also: Customs.

The fourth risk is assuming component compliance equals finished-product compliance. A component declaration helps, but the final product may include packaging, accessories, spare parts, cables, batteries, coatings, or added labels that were not covered by the component supplier’s statement. The final product assembler or importer should check the full placed-on-market configuration.

The fifth risk is confusing EU, UK, China, and customer-specific versions. Different markets may use similar names but different legal references, scopes, marking requirements, or reporting formats. A declaration intended for EU trade should not rely only on a generic global statement unless it clearly maps the product to the EU requirements being claimed.

A practical workflow for importers and exporters

Start by defining the product and market. Is the product electrical or electronic equipment within RoHS scope? Is it an article, mixture, spare part, packaging item, or accessory under REACH analysis? Which entity places it on the EU market? The answers determine whether the needed document is a supplier material declaration, a finished-product EU Declaration of Conformity, a REACH Article 33 communication, a SCIP notification record, or several of these together.

Next, request controlled documentation from suppliers. The request should specify the model or part numbers, the RoHS legal reference, the REACH Candidate List date, Annex XVII applicability, and any required supporting evidence. Avoid accepting a declaration that covers all products made by a supplier unless the supplier can show that the covered products share the same materials and controls.

Then compare the declaration against purchasing reality. Check whether the document covers the exact revision, color, cable type, plug type, coating, adhesive, and packaging used in the shipment. Small changes can matter. A black plastic housing may have a different pigment package than a white housing. A flame-retarded connector may carry different REACH risks than an unfilled plastic bracket.

Finally, set update triggers. Review declarations when the Candidate List changes, when RoHS exemptions change, when the product design changes, when a supplier changes material or production site, or when a customer asks for a narrower declaration. For high-risk products, an annual refresh may not be enough if there are frequent material substitutions or regulatory changes.

Suggested wording approach

A strong declaration uses precise language. For RoHS, the statement may say that, based on supplier declarations, material data, testing where applicable, and technical documentation, the identified products comply with the maximum concentration values of Directive 2011/65/EU as amended, in homogeneous materials, except for any listed exemptions. If exemptions apply, they should be named in a separate line.

For REACH, the statement should avoid claiming total REACH compliance unless the issuer truly controls registration, restriction, authorisation, SVHC communication, and all relevant downstream obligations. For many finished goods, a narrower statement is safer: the issuer has assessed the identified articles against the Candidate List as of a stated date and either no Candidate List SVHC is present above 0.1% w/w in any article, or the SVHC name, article location, safe-use information, and SCIP status are disclosed.

The declaration should also include a limitation clause. It can state that the conclusion is based on information available as of the issue date and remains valid only while product design, materials, suppliers, and applicable regulations remain unchanged. This does not weaken the document; it makes the compliance claim more honest and auditable.

Frequently asked questions

Is a RoHS and REACH compliance declaration the same as a test report?

No. A declaration is a responsible statement by the issuer. A test report is one type of evidence that may support the statement. For complex products, a stronger file usually combines supplier declarations, material data, targeted testing, bill of materials review, and a process for regulatory updates.

Can one declaration cover both RoHS and REACH?

Yes, but it should separate the conclusions. The RoHS section should address restricted substances in homogeneous materials for products within RoHS scope. The REACH section should address SVHC communication, Candidate List date, Annex XVII restrictions where applicable, and SCIP implications where SVHCs above 0.1% are present in articles.

Does REACH apply to non-electrical products?

Yes. REACH is not limited to electrical and electronic equipment. It can apply to chemicals, mixtures, packaging, articles, consumer goods, industrial parts, textiles, plastics, coatings, and other traded products depending on substance content and supply-chain role.

How often should declarations be updated?

They should be reviewed whenever product materials, suppliers, legal requirements, Candidate List entries, RoHS exemptions, or customer specifications change. A dated REACH statement is especially important because an old declaration may not reflect later SVHC additions.

What is the most important red flag in supplier declarations?

The strongest red flag is vague wording with no product identification, no legal reference, no Candidate List date, no material-level RoHS basis, and no signatory responsibility. Such a document may be useful as a starting point, but it is not a reliable compliance record for EU import files.