RoHS and REACH certificate of compliance explained for importers

What buyers usually mean by a RoHS and REACH certificate of compliance

When a buyer asks for a RoHS and REACH certificate of compliance, the request is usually for written evidence that a product has been assessed against EU substance-control requirements. It is not a request for one universal EU certificate. RoHS and REACH are separate legal frameworks, and they create different duties for manufacturers, importers and suppliers.

RoHS focuses mainly on restricted hazardous substances in electrical and electronic equipment. REACH is a wider chemicals regulation covering substances, mixtures and articles, including communication duties for substances of very high concern. A workable compliance file may include a manufacturer declaration, supplier material declarations, test reports, exemption records and a review date. A test report alone is not the same as a legal declaration, and a one-page certificate with no product identity, scope or supporting evidence is weak for import compliance.

This article summarises public guidance from the European Commission, EUR-Lex, ECHA, IEC and official EU/UK product guidance. It is written for importers, sourcing teams and trade operators who need to review supplier paperwork before shipment.

RoHS and REACH are not the same obligation

RoHS and REACH often appear together in purchase orders because both deal with hazardous substances. In daily trade, however, they answer different questions. RoHS asks whether an electrical or electronic product contains listed restricted substances above maximum concentration values in homogeneous materials, unless an exemption applies. REACH asks broader questions about chemical substances, including whether substances of very high concern, known as SVHCs, are present in articles above the reporting threshold and whether restrictions or authorisation duties apply.

For that reason, a combined certificate should still be read as two declarations in one file. A supplier may have good RoHS testing but poor REACH SVHC tracking. The reverse can also occur where a non-electrical article has REACH obligations but is outside RoHS scope.

What a RoHS compliance declaration should cover

EU RoHS currently restricts ten substances in electrical and electronic equipment. The European Commission identifies them as lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP. Under the amended Annex II limits, cadmium is restricted to 0.01% by weight in homogeneous materials, while the other listed substances are generally restricted to 0.1% by weight, subject to specific exemptions and transitional provisions.

For importers, the phrase homogeneous material is important. A finished product is not assessed only as a complete unit. Plastics, solder, plating, insulation, cable jackets, coatings and other separable materials may each need evidence. A low average concentration across the finished item does not correct a violation in one homogeneous material.

Under the RoHS framework, manufacturers must prepare technical documentation, carry out the required conformity assessment procedure, draw up an EU Declaration of Conformity and affix the CE marking to finished in-scope EEE. EUR-Lex text for Directive 2011/65/EU also states that the technical documentation and EU Declaration of Conformity must be kept for 10 years after the EEE has been placed on the market. Importers have their own checks, including ensuring that the conformity assessment has been carried out, that technical documentation exists, that the product bears CE marking and that a copy of the declaration is available for the same general retention period.

A practical RoHS declaration should include at least the following:

• unique identification of the product, model, series, batch or part numbers covered;
• name and address of the manufacturer or authorised representative;
• a statement that the declaration is issued under the responsible party’s sole responsibility;
• the applicable law, normally Directive 2011/65/EU as amended, and any relevant national implementation for the target market;
• references to harmonised standards or technical specifications used, where applicable;
• any RoHS exemptions used, with exemption number, material or component, expiry relevance and evidence that the exemption still applies;
• place and date of issue, name, function and signature of the responsible person.

Many technical files also refer to EN IEC 63000:2018 for the assessment documentation. The European Commission’s 2020 implementing decision recognised EN IEC 63000:2018 as the harmonised standard for technical documentation supporting RoHS assessment, replacing EN 50581:2012 after its withdrawal date. In practical terms, this standard is not a laboratory test method for every part. It is a structured way to compile and judge the documentation that supports the declaration.

What a REACH statement should cover

REACH is broader than RoHS and should not be reduced to a sentence saying REACH compliant. The European Commission describes REACH as the EU regulation for registration, evaluation, authorisation and restriction of chemicals. For importers of finished goods, two areas commonly appear in supplier declarations: SVHC communication for articles and restrictions under Annex XVII. Depending on the supply chain role and volume, registration or notification duties may also be relevant.

ECHA guidance explains that suppliers of articles containing a Candidate List SVHC above 0.1% weight by weight must provide recipients with enough information to allow safe use, at least naming the substance. Consumers can request similar information, and the supplier must respond free of charge within 45 days. ECHA guidance also treats the 0.1% threshold at the article level. This means a complex object such as an appliance, tool or vehicle part may need evaluation of component articles, not only the assembled product as a whole.

Since 5 January 2021, companies supplying articles on the EU market that contain Candidate List SVHCs above 0.1% weight by weight have also had SCIP database duties under the Waste Framework Directive framework. SCIP does not replace Article 33 communication. It is a separate data-submission system intended to make information on substances of concern available through the product life cycle, including waste treatment.

A useful REACH statement for trade should do more than describe the supplier’s company policy. It should identify the exact product, the date or version of the Candidate List checked, the data collection method, the article-level conclusion, and whether any SVHC is present above 0.1% weight by weight. If an SVHC is present above the threshold, the statement should name the substance and provide safe-use information. If no SVHC is declared above the threshold, the statement should still say whether the conclusion is based on supplier declarations, bill-of-material screening, laboratory testing, material knowledge or a combination of these.

For products made from many purchased parts, a REACH statement can become outdated when the Candidate List changes, when a material formulation changes, when a supplier changes, or when the target market changes. Importers should not rely indefinitely on a certificate with no issue date or Candidate List date.

How importers should evaluate supplier paperwork

Importers do not need to become chemists, but they do need a repeatable document review process. The first check is scope. Is the product electrical or electronic equipment under RoHS, or is it a non-EEE article where RoHS may not apply but REACH still can? Is the shipment going to the EU, Great Britain, Northern Ireland, or another jurisdiction with its own version of RoHS or REACH-like obligations?

The second check is identity. A certificate that covers electronic accessories is not enough if the purchase order is for a specific charger, PCB assembly, cable harness or LED unit. The declaration should match the model number, revision, materials and supplier shown on commercial documents. If the product is private labelled, modified after manufacture or assembled by another party, responsibility may shift, and a factory’s old declaration may not be sufficient. See also: Customs.

The third check is evidence. Useful evidence may include material declarations from upstream suppliers, XRF screening, wet chemistry reports for high-risk materials, bills of materials, exemption analysis and production control procedures. Testing has value, but it has limits. XRF screening may not distinguish every regulated chemical form, and a report for one colour, one cable jacket or one production batch may not cover a later formulation. Laboratory reports should show sample identity, test date, method, measured substances and whether the tested sample matches the product being shipped.

The fourth check is update control. RoHS exemptions can expire or change, and the REACH Candidate List is updated periodically. A strong supplier file states when it must be reviewed. Review triggers should include product design changes, material changes, supplier changes, new regulatory restrictions, updated SVHC lists and new customer market requirements.

For broader trade documentation topics, see the Compliance section on dumbopus.com.

Common red flags in RoHS and REACH certificates

Several red flags appear repeatedly in import files. One is a document called a certificate that does not identify the product, model, manufacturer or date. Another is a lab report used as if it were an EU Declaration of Conformity. A lab can test a submitted sample, but the responsible economic operator still needs to evaluate the product, control production and issue the correct declaration where required.

A second red flag is a REACH statement that refers to an old SVHC list or gives no Candidate List date. Because the Candidate List changes over time, a declaration made several years earlier may not support a current shipment. A third red flag is a RoHS declaration that ignores exemptions. If lead, cadmium or another restricted substance is present under an exemption, the file should say which exemption applies and why it remains valid for the product category and placing-on-market date.

A fourth red flag is a certificate that claims worldwide compliance without naming laws. EU RoHS, UK RoHS, China RoHS, UAE RoHS and other substance-control systems do not use identical documentation models. A broad claim may be useful as a cover note, but it should not replace jurisdiction-specific assessment.

Finally, be cautious with documents sold as CE certificates for products that rely on manufacturer self-assessment. Official EU guidance from Your Europe notes that there is no central EU body that grants permission or a certificate allowing use of the CE mark. The responsible party must identify applicable rules, gather technical evidence, complete the required conformity assessment, draw up the declaration and keep documentation available for authorities.

A practical document set before shipment

For a routine shipment of in-scope electronic goods to the EU, a practical pre-shipment file often includes:

• signed RoHS EU Declaration of Conformity or combined EU Declaration of Conformity that clearly includes RoHS;
• RoHS technical documentation summary, including EN IEC 63000:2018 reference where used;
• current RoHS test reports or material declarations for high-risk components and homogeneous materials;
• exemption analysis, if any restricted substance is intentionally present under an allowed exemption;
• REACH SVHC statement showing the Candidate List date checked and article-level conclusion;
• Annex XVII restriction review for substances relevant to the product type, material and market;
• SCIP submission information where Candidate List SVHCs above 0.1% are present in articles placed on the EU market;
• change-control commitment requiring the supplier to notify material, design, formulation and sub-supplier changes.

This set will not fit every product. Batteries, toys, food-contact materials, medical devices, machinery, wireless equipment and packaging may bring additional rules. The value of the list is that it separates the declaration, the evidence, the market duty and the update trigger. That separation is what many weak certificates fail to do.

Frequently asked questions

Is a RoHS and REACH certificate legally required for every import?

Not as a single combined document. For in-scope EU electrical and electronic equipment, RoHS conformity documentation and an EU Declaration of Conformity are central. For REACH, the required evidence depends on the product, substances, market role and thresholds. Buyers often request a combined certificate for convenience, but the legal duties behind it remain separate.

Can one laboratory test report prove RoHS and REACH compliance?

No. A test report can support a conclusion for the tested sample and substances tested. It does not automatically prove ongoing production compliance, all materials, all colours, all suppliers or all REACH obligations. It should be part of a technical file, not the whole file.

How often should suppliers update REACH declarations?

At minimum, update them when the Candidate List changes, when materials or suppliers change, when the product is redesigned, or when a new target market requires a different assessment. A statement with no issue date or Candidate List date should be treated as incomplete.

Does RoHS apply to non-electrical products?

Generally, RoHS is focused on electrical and electronic equipment and certain related items. Non-electrical articles may still have REACH duties, packaging requirements or other chemical restrictions. Scope should be checked before asking for the wrong certificate.

What is the safest way to request documents from a supplier?

Ask for product-specific documents by model number and destination market. Request the RoHS declaration, supporting technical documentation or test evidence, REACH SVHC statement with Candidate List date, any exemption analysis, and confirmation that the supplier will notify you before material or component changes.