REACH and RoHS compliance statement for importers and exporters
A REACH and RoHS compliance statement is a controlled business document that records whether defined goods meet the relevant EU chemical and hazardous substance requirements. For importers and exporters, it should do more than state “compliant.” It should identify the products covered, name the applicable rules, describe the substance scope, refer to the evidence reviewed, list any exemptions or exclusions, and show the review date. REACH and RoHS are often requested together, but they are not the same law. REACH deals broadly with chemicals, substances in articles, SVHC communication, restrictions, and authorisation. RoHS applies mainly to electrical and electronic equipment and restricts certain substances at the homogeneous material level. A well-drafted statement helps buyers, customs-facing teams, distributors, and compliance reviewers understand what has been checked and what still depends on supplier or laboratory evidence.
What a REACH and RoHS compliance statement should actually do
A compliance statement is not a universal certificate, and it should not read like a vague promise. Its role is to communicate the compliance position of specified products at a specific point in time. In import and export trade, it is often requested during supplier onboarding, shipment preparation, tender review, retail listing, CE technical file collection, or distributor due diligence.
The strongest statements are specific. They identify the product name, model number, part number, revision, batch if relevant, manufacturer or supplier, issuing company, issue date, and the regulations being addressed. They also explain whether the conclusion is based on supplier declarations, bill of materials review, material declarations, test reports, or a risk-based assessment.
A weak statement says only that “all products are REACH and RoHS compliant.” That wording is usually too broad, especially when a company trades multiple product families, sources components from different suppliers, or sells both electronic and non-electronic goods. A better statement defines the scope and the limits of the conclusion.
The core difference between REACH and RoHS
REACH and RoHS are often grouped together because both address hazardous substances. In practice, they answer different compliance questions. REACH asks whether chemical substances are registered, restricted, authorised, or subject to communication duties. RoHS asks whether electrical and electronic equipment contains certain restricted substances above maximum concentration values in homogeneous materials.
| Topic | REACH | RoHS |
|---|---|---|
| Main legal focus | Chemical substances, mixtures, articles, restrictions, authorisation, and supply chain communication | Restriction of hazardous substances in electrical and electronic equipment |
| Typical product relevance | Broad range of goods, including articles such as accessories, packaging components, consumer goods, machinery parts, plastics, metals, textiles, and coatings | Electrical and electronic equipment and many components used in such equipment |
| Common threshold concept | SVHC communication duties commonly use 0.1% weight by weight in an article | Maximum concentration values apply at homogeneous material level |
| Key business evidence | Supplier declarations, SVHC screening, substance declarations, SDS where relevant, restriction checks, SCIP assessment for EU market articles where applicable | Bill of materials, material declarations, supplier declarations, risk assessment, test reports, and technical documentation |
| Frequent mistake | Treating a finished product average as the relevant SVHC basis | Testing only the finished product without considering homogeneous materials and exemptions |
According to the European Commission, REACH is the main EU law for managing chemical risks and places responsibility on industry to manage those risks and provide safety information. ECHA’s public Candidate List table showed 253 entries after the 4 February 2026 update. Because the Candidate List can change, a statement should say which list date or review date was used.
For RoHS, the EU regime is based on Directive 2011/65/EU as amended, including the Annex II substance list amended by Commission Delegated Directive (EU) 2015/863. The commonly referenced restricted substances are lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP, subject to maximum concentration values and applicable exemptions. A statement should not ignore exemptions, as many electronics categories have time-limited or use-specific exemptions that need careful review.
When importers and exporters are asked for the statement
In cross-border trade, a buyer may ask for a REACH and RoHS compliance statement before issuing a purchase order. A marketplace, distributor, or brand owner may request the same document before listing a product. For electrical and electronic equipment entering the EU market, RoHS documentation can form part of broader conformity assessment and technical documentation work. For non-electronic goods, RoHS may be irrelevant, but REACH may still apply if the product is an article, contains restricted substances, includes chemical mixtures, or uses materials likely to contain SVHCs.
Exporters outside the EU should be careful with wording. A non-EU exporter may not be the EU importer of record, but its documents often support the EU importer’s legal obligations. The statement should therefore avoid claiming that the exporter has completed every EU importer duty unless that is actually the case. More accurate wording may say that the supplier has reviewed the listed products against the specified REACH and RoHS requirements based on available supply chain and testing evidence.
Importers should also remember that a supplier statement is evidence, not a complete compliance system. If a regulator or customer challenges the product, the importer may need supporting records such as technical files, test reports, material declarations, supplier contracts, purchase specifications, and change-control records.
Evidence that should sit behind the statement
A credible statement is only as strong as the evidence behind it. For many traded goods, that evidence does not come from one document. It usually combines supplier declarations, bill of materials data, component-level information, material declarations, and targeted testing where the material or supplier risk is higher.
Supplier declarations and material declarations
Supplier declarations are useful, but they should be product-specific and current. A generic declaration downloaded from a supplier website may not identify the exact model, revision, material, or production site. Material declarations are more useful when they name substances, CAS numbers where applicable, concentration ranges, and the component or material location.
Laboratory testing
Testing can support compliance, especially for higher-risk materials such as PVC, solder, pigments, coatings, cables, flame-retarded plastics, plated metals, and recycled materials. Testing every substance in every product lot is rarely practical. A risk-based approach is common: companies test materials or components where restricted substances are more likely, then combine the results with supplier controls and purchasing specifications.
Bill of materials and product change control
A REACH or RoHS statement can become outdated when a supplier changes a resin, coating, solder, cable, pigment, plasticizer, adhesive, plating process, or recycled content source. Import/export teams should connect compliance statements with engineering change notices, approved supplier lists, and purchasing records. If the bill of materials changes, the statement may need review before the next shipment.
SCIP and SVHC review for EU articles
For articles placed on the EU market, ECHA’s SCIP requirements can be triggered where an article contains a Candidate List SVHC above 0.1% weight by weight. ECHA states that companies supplying such articles on the EU market have had to submit information to the SCIP database from 5 January 2021. This does not mean every exported product requires a SCIP submission by the non-EU supplier, but it does mean EU importers and distributors often need article-level substance information from upstream suppliers.
Recommended content for a statement
A practical REACH and RoHS compliance statement should include enough detail for a reviewer to understand the scope without reading a long technical file. The following structure suits many trade documents, although companies should adapt it to their products and legal role. See also: Customs.
- Document title: Use a clear title such as “REACH and RoHS compliance statement.”
- Issuing company: Name the company issuing the statement and its address or responsible department.
- Product scope: List product names, model numbers, SKUs, part numbers, revisions, and covered accessories if applicable.
- Market scope: State whether the statement is intended for the EU, EEA, UK, or another market. Do not assume EU and UK requirements are always identical.
- REACH position: Address Candidate List SVHC review, Article 33 communication status where relevant, Annex XVII restriction review where relevant, and any known substances requiring disclosure.
- RoHS position: State whether the products are electrical or electronic equipment, identify the directive basis, address the restricted substances, and note applicable exemptions if used.
- Evidence basis: Identify whether the conclusion is based on supplier declarations, material declarations, test reports, technical documentation, or risk assessment.
- Limitations: Explain that the statement applies only to the listed products and issue date, and that changes in materials, suppliers, or regulations may require reassessment.
- Signature and date: Include a responsible person, title, signature or electronic approval, and issue date.
The wording should be clear, but not overconfident. Instead of saying “all products will always comply,” a more defensible statement says that, based on available evidence as of the issue date, the listed products comply with the specified requirements, subject to stated exemptions and no material or supplier changes.
Common mistakes that delay shipments
The first mistake is mixing up the REACH SVHC threshold with the RoHS homogeneous material threshold. REACH communication duties for SVHCs in articles are commonly assessed at article level, while RoHS maximum concentration values apply to homogeneous materials. A finished-product average is not a reliable substitute for either assessment.
The second mistake is using the phrase “RoHS 3” without explaining the legal basis. Many buyers use “RoHS 3” informally to refer to the 2015 amendment that added four phthalates, but formal documents should reference Directive 2011/65/EU as amended, including Commission Delegated Directive (EU) 2015/863 where relevant.
The third mistake is forgetting exemptions. RoHS exemptions are not a blanket permission. They are tied to defined applications, product categories, and expiry conditions. If a product relies on an exemption, the statement should identify it rather than hide it.
The fourth mistake is allowing statements to go stale. Because the REACH Candidate List can be updated and product materials can change, a statement issued years earlier may not satisfy a careful buyer. Importers should request updated statements when regulations change, when suppliers change, or when components are revised.
The fifth mistake is treating packaging as an afterthought. Packaging can raise its own chemical and material compliance questions. If packaging is included in the statement, say so. If the statement covers only the product and excludes packaging, state that clearly.
A practical workflow for trade teams
Import/export teams do not need to turn every shipment file into a scientific dossier, but they do need a repeatable process. Start by classifying the product: Is it electrical or electronic equipment? Is it an article, mixture, spare part, accessory, or packaging component? Then map the applicable REACH and RoHS obligations for the intended market.
- Collect product identifiers, drawings, specifications, and bill of materials information.
- Ask suppliers for current, product-specific REACH and RoHS declarations.
- Request material declarations or test reports for high-risk components and materials.
- Check whether any SVHCs, restricted substances, or RoHS exemptions are relevant.
- Review whether EU SCIP information may be needed for articles containing Candidate List SVHCs above the threshold.
- Draft the statement with clear scope, evidence basis, limitations, and issue date.
- Set a review trigger for regulatory updates, supplier changes, and material changes.
For broader trade documentation and regulatory topics, see the Compliance section. The key editorial point for any business document is consistency: the statement, test reports, product labels, purchase specifications, and customer declarations should not contradict each other.
Frequently asked questions
Is a REACH and RoHS compliance statement the same as a certificate?
Not necessarily. Many buyers call it a certificate, but it is usually a supplier or manufacturer declaration. It should be supported by evidence, but the statement itself is not automatically a third-party certification unless an accredited or qualified body has issued a separate certificate.
Does every product need both REACH and RoHS wording?
No. REACH can apply broadly to substances, mixtures, and articles, but RoHS is mainly relevant to electrical and electronic equipment. A non-electronic product may need a REACH statement while RoHS is marked as not applicable. If a product includes electronic accessories, cables, chargers, batteries, or control units, RoHS relevance should be reviewed carefully.
Do importers always need laboratory testing?
Not always. Testing is one form of evidence, but a compliance file may also rely on supplier declarations, material declarations, technical documentation, and risk assessment. Testing is more important where materials are high risk, supplier data is incomplete, or the buyer requires independent evidence.
How often should the statement be updated?
Update it when the product design, material, supplier, production site, or regulatory list changes. For REACH, the Candidate List should be checked before issuing or renewing a statement. For RoHS, exemptions and substance restrictions should be reviewed for the relevant product category and market.
Can one statement cover multiple products?
Yes, if the products are clearly listed and share a reliable evidence basis. A family-level statement should include model numbers or SKUs and define what is included. It should not cover unrelated products with different materials, suppliers, or electronic components unless each has been reviewed.
