REACH RoHS compliance declaration PDF requirements for importers

A declaration PDF is a gatekeeping document, not the whole compliance file

A REACH RoHS compliance declaration PDF is commonly requested to show that a supplier has considered EU chemical and hazardous-substance requirements before goods are placed on the market. For importers, it creates a clear record that can be shared with buyers, marketplaces, logistics partners, and internal compliance teams. The PDF alone, however, does not prove compliance. It should summarize a traceable assessment supported by bills of materials, supplier material declarations, laboratory reports where needed, exemption reviews, and change-control records.

The main point is that REACH and RoHS are separate regimes. REACH applies broadly to substances, mixtures, and articles under Regulation (EC) No 1907/2006. RoHS applies to electrical and electronic equipment under Directive 2011/65/EU, as amended, and is tied to CE conformity duties. A combined PDF can be practical, but it should not merge the two legal tests or imply that compliance with one regulation proves compliance with the other.

For more trade compliance background, see the Compliance section.

How REACH and RoHS differ in a supplier declaration

REACH and RoHS are often requested together because traded goods may contain plastics, metals, coatings, cables, circuit boards, batteries, packaging elements, or other components that raise chemical compliance questions. That does not make the requirements interchangeable. A strong declaration should state which regulation is being addressed, which product is covered, and what evidence supports the statement.

Because the REACH Candidate List changes over time, a declaration that only says “REACH compliant” without a Candidate List date is weak. Because RoHS depends on product scope and homogeneous materials, a statement that only says “RoHS passed” without part numbers, substance coverage, or a technical basis is also weak.

What a REACH section should include

A practical REACH section in a PDF should identify the company making the declaration, the products covered, and the legal basis considered. It should also state whether the product is a substance, mixture, article, or complex object. For many import-export transactions involving finished goods, the key question is whether any article contains a Substance of Very High Concern on the ECHA Candidate List above 0.1% weight by weight.

If the supplier declares that no Candidate List SVHC is present above the threshold, the PDF should state the date of the Candidate List reviewed. This is important because the list is updated over time. If a Candidate List substance is present above the threshold, the declaration should name the substance and provide available safe-use information. Under REACH Article 33, business recipients must receive sufficient information available to the supplier, at least the substance name, when the 0.1% threshold is exceeded. Consumers can also request relevant information and must receive it free of charge within 45 days.

Importers should also look beyond the Candidate List. REACH Annex XVII restrictions can apply to specific substances in certain products, uses, or materials. Examples across the regulation include restrictions affecting phthalates in plasticised material, certain heavy metals, azo colorants, nickel release, and other substance-use scenarios. A declaration that covers only SVHC status may not answer whether an Annex XVII restriction applies.

For articles supplied on the EU market, SCIP duties may also arise when Candidate List substances above 0.1% weight by weight are present. Since 5 January 2021, companies supplying such articles in the EU have had to submit information to ECHA’s SCIP database under the Waste Framework Directive framework. A non-EU exporter may not be the direct EU duty holder, but its information often determines whether the EU importer can submit accurate data.

What a RoHS section should include

A RoHS section is relevant when the product falls within the scope of electrical and electronic equipment. The EU RoHS Directive restricts specified hazardous substances in homogeneous materials. A homogeneous material is a material that cannot be mechanically disjointed into different materials, such as a plastic casing, solder alloy, coating layer, or metal part. This is why RoHS is not assessed as a whole-product average.

As amended by Commission Delegated Directive (EU) 2015/863, RoHS covers ten restricted substances: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP. The maximum concentration value is generally 0.1% by weight in homogeneous materials, except cadmium at 0.01%. The four phthalate restrictions have applied to most EEE from 22 July 2019, and to medical devices and monitoring and control instruments from 22 July 2021.

For finished EEE, RoHS is connected to CE conformity. Directive 2011/65/EU requires an EU declaration of conformity that follows the model structure in Annex VI. A proper declaration should identify the product, manufacturer or authorised representative, the object of the declaration, the directive, relevant harmonised standards or technical specifications, additional information where needed, place and date of issue, and the name, function, and signature of the responsible person.

Importers should pay close attention to the standards cited. EN IEC 63000:2018 is the harmonised standard commonly used for technical documentation supporting RoHS substance restriction assessments. It does not mean that every material must automatically be tested; it supports a risk-based technical file using supplier evidence, material information, and test reports where appropriate. If a supplier cites an outdated or irrelevant standard, request clarification before relying on the declaration.

Minimum checklist for a reliable PDF

A reliable declaration does not need to be long, but it should be specific enough for a third party to understand what was assessed. The following checklist helps importers decide whether a PDF is usable as submitted or whether more evidence is needed.

• Exact product identification: Include model number, SKU, part number, revision, series, or product family boundaries. Avoid broad statements that cannot be tied to the shipped goods.
• Manufacturer or supplier identity: State the legal company name, address, and contact point responsible for the declaration.
• Regulation names: Refer to Regulation (EC) No 1907/2006 for REACH and Directive 2011/65/EU as amended for RoHS, where applicable.
• REACH Candidate List date: State the date on which the SVHC Candidate List was checked.
• SVHC result: Say whether Candidate List substances are above 0.1% weight by weight in any article. If yes, name the substance and provide safe-use information.
• Annex XVII review: Address relevant restrictions if the product type, material, or intended use makes them plausible.
• RoHS substance coverage: Cover all ten restricted substances, not only the older six-substance list.
• Exemptions: If compliance depends on an exemption, identify the exemption number, scope, and expiry or review status.
• Technical basis: Summarize whether the statement is based on supplier declarations, material declarations, risk assessment, testing, or a combination.
• Issue date and signature: Include date, place if relevant, name, position, and signature or controlled electronic approval.

For routine sourcing, importers can adapt this checklist into a supplier onboarding questionnaire. For higher-risk goods, the declaration should be backed by technical documents rather than treated as a stand-alone certificate.

When a declaration is not enough

A PDF may be acceptable for low-risk goods from a mature supplier with stable materials and clear traceability. It becomes insufficient when risk indicators appear. Higher-risk examples include soft PVC, coated metal accessories, painted children’s products, low-cost electronics, cables, chargers, soldered assemblies, recycled plastic content, articles with direct and prolonged skin contact, or products sold into sensitive EU channels. See also: Customs.

A declaration is also not enough when the supplier cannot explain the evidence behind it. For RoHS, an importer may need component-level material declarations, XRF screening, wet-chemical test reports, or a technical file aligned with EN IEC 63000:2018. For REACH, additional evidence may include material composition statements, substance absence declarations from upstream suppliers, Safety Data Sheets for mixtures, and Annex XVII restriction checks for relevant materials.

Testing should be used intelligently. A single lab report for one sample does not automatically cover every production lot, color, supplier change, or material revision. Conversely, testing every part may be inefficient if the supplier has strong material controls and credible upstream declarations. The goal is proportional evidence: the higher the chemical risk, the deeper the documentation should be.

Common red flags in REACH and RoHS PDFs

Importers should review declarations with a practical but critical eye. The following red flags often mean the document should be corrected before shipment or before submission to a buyer.

• The document says “RoHS 3 compliant” but does not list the ten restricted substances or the applicable directive amendment.
• The REACH statement has no Candidate List date.
• The PDF uses broad wording such as “all products are compliant” without product identifiers.
• The declaration is issued by a trading company that cannot connect the statement to the actual manufacturer or bill of materials.
• RoHS is claimed for a non-electrical product without explaining why the directive applies.
• An exemption is mentioned without an exemption number, scope, or expiry review.
• Test reports are older than the material revision, supplier change, or design change.
• The declaration is unsigned, undated, or issued by an unknown entity.
• The document states “REACH compliant” but ignores Annex XVII restrictions relevant to the product material or use.

These issues do not always mean the product is non-compliant. They mean the declaration is not strong enough to support an importer’s due-diligence file without follow-up.

Practical workflow for import-export teams

A workable compliance workflow starts before purchase orders are issued. First, classify the product: Is it EEE? Is it an article, mixture, or substance? Does it include plastics, coatings, metals, electronics, textiles, leather, adhesives, batteries, or packaging that may trigger chemical restrictions? Second, request the correct document type. For EEE, ask for RoHS technical support and an EU declaration of conformity where relevant. For REACH, ask for SVHC status, Candidate List date, and a restriction review for the product’s materials and use.

Third, match the declaration to the shipment. The model number, revision, supplier name, and date should correspond to the invoice, packing list, purchase order, and product label. Fourth, store the PDF with its supporting evidence. A clean folder structure can save time during buyer audits or market-surveillance questions.

Finally, set review triggers. Update the file when the Candidate List changes, when a supplier changes material or production site, when the product design changes, when a RoHS exemption is near expiry, or when a buyer requests a newer declaration. Chemical compliance is not a one-time download; it is a controlled supply-chain process.

Frequently asked questions

Is a combined REACH and RoHS declaration acceptable?

Yes, a combined PDF can be acceptable for commercial due diligence if it clearly separates REACH and RoHS statements. The document should not imply that one regulation proves compliance with the other. REACH and RoHS have different scopes, thresholds, evidence needs, and legal consequences.

Does every product need RoHS documentation?

No. RoHS applies to electrical and electronic equipment within the directive scope. A purely mechanical item may still need REACH review, but it may not need a RoHS declaration unless it is part of an in-scope EEE supply chain or a buyer contract specifically requires material information.

How often should a REACH declaration be updated?

There is no single commercial interval that fits all products, but the declaration should be reviewed when the Candidate List is updated, when materials change, or when a customer requires a current statement. The date of the Candidate List checked is essential.

Is a lab report better than a declaration?

A lab report is evidence, while a declaration is a responsibility statement. For many products, the strongest file includes both: a signed declaration plus selected test reports, material declarations, and supplier records that explain how the conclusion was reached.

Can an importer rely entirely on a supplier PDF?

Importers can use supplier declarations as part of due diligence, but relying entirely on an unsupported PDF is risky. The importer should check product identity, regulatory scope, dates, exemptions, and whether the supplier can provide evidence if challenged by a buyer or authority.