RoHS Directive Guide

Your EU distributor has just asked you to confirm that your next container of electronics is RoHS 3 compliant, with a Declaration of Conformity and technical documentation ready for CE Marking and EU import. Your supplier is a PCBA factory in Shenzhen, a plastics moulder in Dongguan or a charger plant in Zhongshan, and the paperwork on your desk is a one-line "RoHS compliant" claim. This guide gives you the full working picture: the 10 restricted substances and their exact limits, the 11 product categories in scope, the IEC 62321 test methods, the documentation stack, and the factory-side workflow that turns a paper claim into verifiable compliance before the container ships.

Key takeaways for importers:

• RoHS restricts 10 substances in electrical and electronic equipment (EEE), measured by weight in each homogeneous material: nine at 0.1% and cadmium at 0.01%.
• RoHS 3 (Commission Delegated Directive (EU) 2015/863) added four phthalates, effective 22 July 2019 for most categories and 22 July 2021 for medical devices and monitoring instruments.
• There is no mandatory third-party RoHS certification: the manufacturer self-declares via a Declaration of Conformity supported by technical documentation per EN IEC 63000:2018, kept for 10 years.
• Testing follows the IEC 62321 series: XRF screening at the factory, ICP-OES, colorimetric and GC-MS confirmation at an accredited laboratory.
• RoHS is one of roughly 25 CE Marking directives and regulations: most EEE also falls under Low Voltage, EMC or Radio Equipment rules, and the DoC must list them all.
• Compliance is won or lost at the Chinese factory: BOM review, material declarations, XRF pre-screening and DoC verification before shipment.

What Is the RoHS Directive? (2011/65/EU, Legal Authority, and Why It Exists)

The RoHS Directive is the EU legal instrument that restricts the use of certain hazardous substances in electrical and electronic equipment (EEE). The current version is Directive 2011/65/EU (known as the RoHS 2 recast), which entered into force on 21 July 2011, as amended by Commission Delegated Directive (EU) 2015/863 (known as RoHS 3), which added four phthalates to the list of restricted substances.

Milestone	Legal act	Key date
RoHS 1	Directive 2002/95/EC	Effective 1 July 2006
RoHS 2 (recast)	Directive 2011/65/EU of 8 June 2011	In force 21 July 2011
RoHS 3 (amendment)	Commission Delegated Directive (EU) 2015/863 of 31 March 2015	Effective 22 July 2019 (22 July 2021 for categories 8 and 9)

RoHS was created because lead, mercury, cadmium and other hazardous substances in discarded EEE were ending up in landfills and incinerators, contaminating the environment and creating public health risks. It works upstream, at the design and manufacturing stage, and forms a pair with the WEEE Directive 2012/19/EU, which governs end-of-life collection and recycling downstream. RoHS makes the waste stream cleaner; WEEE manages what remains.

Two legal precisions matter for importers. First, RoHS is a Directive, not a Regulation: each EU Member State transposes it into national law, so the Annex II restrictions are identical everywhere but control procedures and sanctions can vary by country. Second, the text is structured as 26 articles and 7 annexes. The provisions you will deal with in practice are Article 4 (restrictions), Article 7 (obligations of manufacturers, including the DoC and the CE mark), Article 9 (obligations of importers), Article 15 (conformity assessment), Annex I (11 EEE categories), Annex II (10 restricted substances), Annexes III and IV (exemptions) and Annex VI (the EU Declaration of Conformity template).

RoHS 3 Explained: Commission Delegated Directive (EU) 2015/863 and the Four Added Phthalates

RoHS 3 is the industry shorthand for Commission Delegated Directive (EU) 2015/863 of 31 March 2015, which amended Annex II of the RoHS 2 recast Directive 2011/65/EU to add four phthalates to the list of restricted substances. The restriction became effective on 22 July 2019 for categories 1 to 7, 10 and 11, and on 22 July 2021 for category 8 (medical devices) and category 9 (monitoring and control instruments).

No official EU text uses the term "RoHS 3": it is a market shorthand for the 2015/863 Annex II update, and your documentation should always reference the underlying legal acts.

Phthalate added by RoHS 3	Abbreviation	CAS number	Limit
Bis(2-ethylhexyl) phthalate	DEHP	117-81-7	0.1%
Butyl benzyl phthalate	BBP	85-68-7	0.1%
Dibutyl phthalate	DBP	84-74-2	0.1%
Diisobutyl phthalate	DIBP	84-69-5	0.1%

These four substances are classified as CMR (carcinogenic, mutagenic or reprotoxic) under the CLP Regulation and have long been used as plasticisers in flexible PVC cable insulation, connectors, seals and gaskets. Their inclusion aligns the EEE regime with the existing REACH Annex XVII restriction on the same phthalates. The staggered timeline gave categories 8 and 9 two extra years for additional medical testing.

The practical consequence: any EEE placed on the EU market since 22 July 2019 (or 22 July 2021 for categories 8 and 9) must comply with all 10 substances, phthalates included. Pre-existing stock could be sold under the previous rules, but current production cannot. A Chinese EEE factory whose DoC and technical documentation have not been updated since 2018 is almost certainly still working to the RoHS 2 six-substance version, and is not compliant.

The 10 Restricted Substances of RoHS 3 and Their Concentration Limits (Annex II)

Annex II of Directive 2011/65/EU as amended by Commission Delegated Directive (EU) 2015/863 lists 10 restricted substances with a maximum concentration value tolerated by weight in each homogeneous material. Compliance is assessed at the homogeneous material level, not at the finished product level.

#	Substance	Symbol / abbreviation	Max concentration (%)	Added by
1	Lead	Pb	0.1	RoHS 1 (2002/95/EC)
2	Mercury	Hg	0.1	RoHS 1 (2002/95/EC)
3	Cadmium	Cd	0.01	RoHS 1 (2002/95/EC)
4	Hexavalent chromium	Cr VI	0.1	RoHS 1 (2002/95/EC)
5	Polybrominated biphenyls	PBB	0.1	RoHS 1 (2002/95/EC)
6	Polybrominated diphenyl ethers	PBDE	0.1	RoHS 1 (2002/95/EC)
7	Bis(2-ethylhexyl) phthalate	DEHP	0.1	RoHS 3 (2015/863)
8	Butyl benzyl phthalate	BBP	0.1	RoHS 3 (2015/863)
9	Dibutyl phthalate	DBP	0.1	RoHS 3 (2015/863)
10	Diisobutyl phthalate	DIBP	0.1	RoHS 3 (2015/863)

The limits are 0.1% (1,000 ppm) by weight for nine substances and 0.01% (100 ppm) for cadmium, measured in the homogeneous material. The Directive defines a homogeneous material as a material of uniform composition throughout, or a material consisting of a combination of materials that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. A moulded plastic housing is one homogeneous material; a zinc-plated screw contains two (the base steel and the coating); a cable contains several (copper conductor, PVC or XLPE insulation, jacket); a PCBA solder joint is one (a Sn-Ag-Cu lead-free alloy or a Sn-Pb leaded one). A typical smartphone, LED bulb, wearable or small appliance contains between 20 and 200 distinct homogeneous materials depending on complexity.

Substance	Where it historically appears in EEE
Lead (Pb)	Solder (Sn-Pb alloy, replaced by lead-free Sn-Ag-Cu), glass of cathode ray tubes (obsolete), legacy PVC stabilisers, brass alloys in bearings and connectors
Mercury (Hg)	Fluorescent and cold cathode fluorescent lamps, some switches and relays; largely replaced by LED lighting
Cadmium (Cd)	NiCd batteries (largely replaced by NiMH and Li-ion), plating (replaced by zinc plating), legacy pigments and PVC stabilisers
Hexavalent chromium (Cr VI)	Chromate conversion coatings on metal parts, dyes and pigments, leather processing
PBB / PBDE	Flame retardants in plastic housings (replaced by phosphorus-based or alternative flame retardants outside the PBDE list)
DEHP / BBP / DBP / DIBP	PVC plasticisers in cables, connectors, gaskets and membranes (replaced by non-phthalate plasticisers such as DINP, DIDP, DPHP)

Aggregate risk concentrates predictably: a typical PCBA carries lead risk in the solder, bromine risk in the FR-4 substrate flame retardant, and cadmium or Cr VI risk in connector plating and hardware. A typical power cable carries DEHP/DBP risk in the flexible PVC insulation. An LED module carries lead risk in solder and cadmium risk in semiconductor phosphors. A charger combines the PCBA and cable risks.

The 11 EEE Product Categories Covered by RoHS (Annex I) and What Falls Outside Scope

Annex I of Directive 2011/65/EU lists 11 categories of electrical and electronic equipment (EEE) covered by RoHS. The 11th category is an open-scope catch-all added by the RoHS 2 recast, meaning any EEE not falling under categories 1 to 10 is nevertheless in scope.

#	Category	Examples of products in scope
1	Large household appliances	Refrigerators, freezers, washing machines, dishwashers, ovens, air conditioners
2	Small household appliances	Vacuum cleaners, coffee makers, toasters, hair dryers, irons, kitchen scales
3	IT and telecommunications equipment	Computers, laptops, printers, smartphones, tablets, routers, servers
4	Consumer equipment	Televisions, monitors, radios, audio equipment, cameras, gaming consoles
5	Lighting equipment	LED bulbs, fluorescent lamps, luminaires, light fittings (household and industrial)
6	Electrical and electronic tools	Power drills, saws, sewing machines, welding equipment (excluding large-scale industrial tools)
7	Toys, leisure and sports equipment	Electric toys, video games, electronic sports equipment, consumer e-scooters
8	Medical devices	Diagnostic equipment, dialysis machines, imaging equipment (subject to Medical Device Regulation 2017/745 in parallel)
9	Monitoring and control instruments	Smoke detectors, thermostats, industrial monitoring, laboratory instruments
10	Automatic dispensers	Vending machines, ATM cash dispensers, ticketing machines
11	Other EEE not covered under other categories	Catch-all: 2-wheeled electric vehicles, e-cigarettes, cannabis vaporisers, electrical cables under 250V, small e-tools not fitting category 6

Article 2 explicitly excludes: military and security equipment, equipment designed to be sent into space, equipment designed to be installed in excluded equipment, large-scale stationary industrial tools, large-scale fixed installations, means of transport (except non-type-approved electric two-wheelers), professional non-road mobile machinery, active implantable medical devices, professionally installed photovoltaic panels, and business-to-business R&D equipment.

Adjacent EU regimes stack on top of RoHS for many products:

• EEE containing lithium batteries: RoHS for the EEE, UN 38.3 for transport of the battery, and EU Battery Regulation 2023/1542 for placing the battery on the market. See the UN 38.3 lithium battery testing guide.
• Electronic toys (category 7): RoHS for the electronic component, EU Toy Safety Regulation 2025/2509 and the EN 71 standards for the finished toy. See the EU Toy Safety Regulation 2025/2509 guide.
• EEE with radio functions (WiFi, Bluetooth, cellular): RoHS plus the Radio Equipment Directive 2014/53/EU and EMC Directive 2014/30/EU. See the CE Marking guide for importers.
• Medical devices (category 8): RoHS plus Medical Device Regulation (MDR) 2017/745 or In Vitro Diagnostic Regulation (IVDR) 2017/746, two parallel mandatory regimes.

Test Methods: IEC 62321 Series (XRF Screening, ICP-OES, GC-MS Confirmation)

Testing electronic products for RoHS compliance follows the IEC 62321 series of international standards. The typical workflow combines rapid non-destructive X-ray fluorescence (XRF) screening at the element level, followed by wet chemistry confirmation testing using ICP-OES for lead, cadmium and mercury, colorimetric methods for hexavalent chromium, and GC-MS for polybrominated biphenyls, polybrominated diphenyl ethers, and phthalates.

Standard	Substance(s)	Test method	Purpose
IEC 62321-1	General	Overview	Introduction to the series
IEC 62321-2	Sample preparation	Disassembly, separation, mechanical	Preparation of homogeneous materials
IEC 62321-3-1	Pb, Hg, Cd, Cr, Br	X-ray fluorescence spectrometry (XRF)	Rapid non-destructive screening at element level
IEC 62321-4	Pb, Cd, Hg	Inductively coupled plasma optical emission spectrometry (ICP-OES)	Confirmation testing of metals
IEC 62321-5	Pb	ICP-OES	Confirmation of Pb specifically
IEC 62321-6	PBB, PBDE	Gas chromatography mass spectrometry (GC-MS)	Confirmation of brominated flame retardants
IEC 62321-7-1	Cr VI in colourless / coloured coatings	Colorimetric	Cr VI specific test
IEC 62321-7-2	Cr VI in polymers / electronics	Colorimetric spot test and boiling water extraction	Cr VI specific test alternative
IEC 62321-8	Phthalates (DEHP, BBP, DBP, DIBP)	GC-MS	Confirmation of RoHS 3 added phthalates

XRF factory-side screening. Portable handheld XRF instruments (Niton XL5 Plus, Bruker S1 Titan, or equivalent) measure Pb, Cd, Hg, Cr and Br directly on the component in seconds, without destroying the sample. The limit: XRF reads the total element, so it cannot distinguish restricted Cr VI from unrestricted Cr III, or bromine in restricted PBB/PBDE from bromine in non-restricted flame retardants such as TBBP-A. An XRF exceedance triggers wet chemistry confirmation.

Confirmation methods. ICP-OES is a destructive high-precision method for Pb, Cd and Hg after acid digestion of the sample. The colorimetric method detects hexavalent chromium specifically, via boiling water extraction and reaction with 1,5-diphenylcarbazide (IEC 62321-7-1 for coatings, 7-2 for polymers and electronics). GC-MS confirms PBB and PBDE (IEC 62321-6) and the four phthalates (IEC 62321-8) after solvent extraction.

For an importer sourcing in China, the implication is direct: your EEE supplier needs access, internal or external, to both tiers. Handheld XRF is increasingly common at mid-size and large Chinese EEE factories; ICP-OES and GC-MS remain the domain of ISO/IEC 17025-accredited laboratories. AQF's CE compliance testing service, chemistry screening service and broader lab testing services cover exactly this two-tier workflow through the ISO/IEC 17025-accredited partner laboratory network that AQF coordinates with.

Exemptions Annex III and Annex IV: Principle, Duration, and How to Read Them

The RoHS Directive provides two lists of exemptions: Annex III applies broadly across product categories, and Annex IV applies specifically to categories 8 (medical devices) and 9 (monitoring and control instruments). Each exemption has a scope, a defined duration, and a review clause; the European Commission updates the lists via delegated directives published in the Official Journal of the EU.

Annex III contains roughly 46 exemptions to date, each describing a specific use where a hazardous-free substitute is not technically or scientifically possible, or where the substitute would create a greater environmental impact. Representative examples:

Exemption	Scope
6(a)	Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35% lead by weight
6(c)	Copper alloy containing up to 4% lead by weight
7(a)	Lead in high melting temperature type solders (lead-based alloys containing 85% by weight or more lead)
15	Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages
34	Cadmium in electrical contacts

Annex IV contains roughly 48 exemptions to date, tailored to critical medical and safety-critical applications, for example lead in glass of X-ray tubes and image intensifiers (exemption 5), lead in flip chip package solders for medical devices (exemption 15), mercury as a cathode dopant for gas discharge lamps used in spectrometry (exemption 45, added by Delegated Directive 2021/1980), lead in metal alloys for bearing and wear surfaces in medical equipment exposed to ionising radiation (exemption 46, added by Delegated Directive 2021/1979), and lead in solders and component terminations for specific medical applications (exemption 47, added by Delegated Directive 2021/1978).

Each exemption is granted for a limited duration: a maximum of 5 years for categories 1 to 7, 10 and 11, and a maximum of 7 years for categories 8 and 9. Renewal requires an application to the European Commission, evaluated by a contracted consortium (Öko-Institut, Fraunhofer IZM), and each delegated directive published in the Official Journal renews or terminates a specific exemption.

The practical rule: any exemption invoked in a Declaration of Conformity must be valid at the moment the product is placed on the market. An expired exemption cannot be used; the product must be reformulated or a new application filed. Because both lists evolve continuously, this guide does not reproduce them in full: the living list and validity dates are published on the European Commission's RoHS page (DG Environment).

RoHS vs REACH vs CE Marking: How the Three EU Frameworks Fit Together for EEE

RoHS, REACH and CE Marking are three distinct but complementary EU frameworks that together govern the chemistry, safety and placing on the market of electrical and electronic equipment (EEE). Understanding how they relate saves importers a great deal of duplicated testing and paperwork.

	RoHS	REACH	CE Marking
Legal basis	Directive 2011/65/EU as amended by 2015/863	Regulation (EC) No 1907/2006	New Legislative Framework, about 25 directives and regulations
Scope	EEE in the 11 Annex I categories	All articles, including but not limited to EEE	Products covered by any CE Marking directive or regulation
Substances	10 fixed substances, updated only by delegated directives amending Annex II	Candidate list of 200+ SVHCs updated twice a year (typically January and June), plus Annex XVII restrictions and Annex XIV authorisations	Varies by directive: electrical safety, EMC, radio, machinery, medical
Proof of conformity	Manufacturer self-declaration (DoC) plus technical documentation; no notified body	Supply chain communication above 0.1% w/w at article level; restriction and authorisation compliance	DoC referencing each applicable directive; notified body only where a specific directive requires it

A few points of detail. REACH imposes SVHC communication down the supply chain above 0.1% w/w at article level, Annex XVII restrictions for specific uses (cadmium, lead in jewellery, phthalates in toys) and Annex XIV authorisation for a small number of substances. For the full REACH picture, see the REACH compliance guide. CE Marking directives relevant to EEE include, alongside RoHS, the Low Voltage Directive 2014/35/EU, the EMC Directive 2014/30/EU, the Radio Equipment Directive 2014/53/EU, the Machinery Directive 2006/42/EC and the Medical Device Regulation 2017/745; see the CE Marking guide for importers for the full framework.

How the three frameworks combine on typical products:

Product	Applicable frameworks	CE mark basis
LED bulb	RoHS, Low Voltage Directive, EMC Directive	DoC referencing all three
WiFi router	RoHS, Radio Equipment Directive (covers LVD and EMC objectives for radio equipment)	DoC referencing RED and RoHS
Smartphone	RoHS, Radio Equipment Directive, REACH SVHC communication if applicable	DoC
Medical device	RoHS, MDR 2017/745, other applicable directives	Notified body certification under MDR plus DoC
PVC-insulated cable	RoHS (phthalates), REACH Annex XVII phthalate restriction, Low Voltage Directive	DoC

The practical implication: a single EEE finished good typically requires a DoC and technical documentation covering RoHS plus LVD plus EMC (or RED for radio equipment). Verify that your Chinese manufacturer's DoC lists all applicable directives, not just RoHS: a DoC referencing only RoHS for a product that also falls under the LVD is incomplete.

Documentation Stack: Declaration of Conformity (DoC), Technical Documentation (EN IEC 63000), CE Mark

RoHS compliance is demonstrated through a self-declaration procedure. The manufacturer prepares a Declaration of Conformity (DoC), assembles the supporting technical documentation, and affixes the CE mark to the product.

EU Declaration of Conformity. Mandatory under Article 13 of Directive 2011/65/EU, following the Annex VI template. It must include:

• Product identification (model, type, batch or serial number).
• Name and address of the manufacturer.
• A statement that the DoC is issued under the sole responsibility of the manufacturer.
• Reference to the applicable Union harmonisation legislation: Directive 2011/65/EU as amended by Commission Delegated Directive (EU) 2015/863.
• References to the harmonised standards applied or the technical specifications used, for example EN IEC 63000:2018.
• Name and function of the signatory, place and date of issue, signature.
• Where several directives apply (RoHS plus LVD, EMC or RED), a single DoC listing all of them is acceptable and preferred.

The DoC should be in the language(s) required by the Member State where the product is placed on the market; English is broadly accepted, but some Member States require a local language version for market surveillance.

Technical documentation. The internal file supporting the DoC must include a general description of the product, conceptual design and manufacturing drawings, explanations necessary to understand those drawings, the list of harmonised standards applied (or the solutions adopted where they were not), the results of design calculations and examinations, and the test evidence: typically ISO/IEC 17025-accredited laboratory test reports on critical homogeneous materials, supplier declarations for other materials, and factory-side XRF screening reports. EN IEC 63000:2018 is the harmonised standard that structures how this file is compiled for hazardous substance restriction. Both DoC and technical documentation must be kept for 10 years after the last product covered is placed on the EU market (Article 7(b)), and produced on request to market surveillance authorities.

CE mark. Per Article 8, the CE mark is affixed to the finished product, its packaging and accompanying documents, with size, format and visibility defined by Regulation (EC) No 765/2008. For RoHS alone no notified body number follows the CE mark; where another directive requires notified body intervention (for example the Radio Equipment Directive under specific modules), the body's four-digit number follows the mark. The CE Marking guide for importers covers the full affixing rules.

A word on "RoHS certification". There is no mandatory third-party RoHS certification under the Directive: manufacturers self-declare. In practice, most Chinese EEE manufacturers commission an ISO/IEC 17025-accredited third-party laboratory to test critical homogeneous materials and issue a test report; that report supports the technical documentation but is not a legal certification. What suppliers call a "RoHS certificate" is usually such a test report. AQF's CE compliance testing service coordinates this testing with its accredited partner laboratory network.

Factory-Side Workflow at Your Chinese EEE Supplier: BOM, XRF, Sampling, DoC

The gap between RoHS on paper and RoHS in the container is a factory-side workflow at the Chinese EEE supplier. Whether you source consumer electronics, LED, chargers, wearables, small appliances or PCBAs, the compliance evidence must be traceable end to end.

1. Supplier vetting and BOM review. Identify the factory that actually produced the product, not the trader. Request the full Bill of Materials (BOM): all components, sub-assemblies, homogeneous materials and material declarations. A typical consumer electronics BOM contains 50 to 500 line items; a common trap is a trader-provided truncated BOM that omits sub-supplier details.
2. Homogeneous material identification and risk prioritisation. From the BOM, map each homogeneous material: plastic housing, metal enclosure, PCBA solder, cable insulation, connector plating, magnets, adhesives, colourants, marking inks. Prioritise by RoHS risk: historically leaded materials (solder, brass, PVC stabilisers), flame-retarded plastics (PBB/PBDE risk), PVC softeners (phthalate risk), plated hardware (Cd/Cr VI risk). A structured factory audit in China guide review, or AQF's factory audit service, covers this verification on site.
3. Material declarations from sub-suppliers. Request declarations for the critical homogeneous materials, in standard formats such as IEC 62474 or IPC-1752A. A supplier declaration alone is not sufficient legal evidence: it must be corroborated by test evidence or trusted supplier certification schemes.
4. XRF factory-side pre-screening. Deploy a portable XRF instrument on the critical homogeneous materials directly at the factory. Non-destructive and rapid, it screens dozens of components per shift and catches gross non-compliance: leaded solder used instead of declared lead-free, brominated flame retardant in a plastic housing. AQF's chemistry screening service performs exactly this step.
5. Third-party laboratory confirmation testing. Send samples of critical homogeneous materials, wherever XRF flagged risk or regulatory-level confirmation is required (Cr VI speciation, phthalate identification, PBDE congener identification), to an accredited third-party laboratory for IEC 62321 series confirmation via AQF's lab testing services.
6. DoC and technical documentation review. Verify the manufacturer's DoC references Directive 2011/65/EU as amended by 2015/863, EN IEC 63000:2018, the correct model, SKU and batch, and the CE mark where other directives apply. Check the technical documentation contains test reports, material declarations and design documents. A first article inspection verifies the first production run matches the certified BOM and DoC (see the first article inspection guide); a pre-shipment inspection verifies CE mark, DoC availability and documentation completeness before the container ships (see the pre-shipment inspection guide and AQF's pre-shipment inspection service).

One stacking note: if your EEE contains lithium batteries, the battery itself also needs UN 38.3 transport testing, covered in the UN 38.3 lithium battery testing guide.

Fraud scenarios to detect at the factory:

• A "RoHS compliant" claim with no supporting test report.
• A test report from a laboratory absent from any ISO/IEC 17025 accreditation register, or a fake report altered from a genuine one.
• A test report covering a different model, SKU, batch or revision than the one being supplied.
• A test report older than 12 months with no evidence of re-testing on current production.
• Leaded solder used in production despite lead-free declared in the BOM (factory-side XRF catches this).
• Recycled plastics containing legacy PBDE flame retardants (XRF flags the bromine, GC-MS confirms the congeners).
• DEHP-containing PVC cables from a secondary supplier not declared in the BOM.
• Mixed batches of compliant and non-compliant units.
• A DoC referencing only RoHS where the product also falls under LVD or EMC.
• A CE mark affixed without complete DoC and technical documentation behind it.

Amazon EU and Retail Angle: What Marketplaces Ask For, and Why

Amazon EU and other major EU retailers of electrical and electronic equipment have overlaid their own chemistry compliance programmes on top of RoHS and CE Marking. Even a properly RoHS compliant product can be delisted or held from sale if the marketplace-level documentation is missing.

Amazon EU chemistry compliance. Amazon.co.uk, Amazon.de, Amazon.fr, Amazon.it and Amazon.es routinely request RoHS attestation and the DoC for electronics listings in categories 3, 4, 5, 6, 7 and 11. Sellers must attest that products meet RoHS and the CE Marking framework and provide the DoC plus supporting test reports on request; failure to respond within the Amazon deadline results in listing suspension. See the Amazon FBA requirements guide.

Fresh test reports. Beyond the manufacturer's DoC, Amazon EU may request a fresh ISO/IEC 17025-accredited laboratory test report on a specific batch, particularly for higher-risk categories such as electronic toys, chargers and wearables. See the Amazon product testing guide.

CE mark visibility. Amazon EU progressively enforces CE mark visibility on listing images. The mark must appear on the product or, where size makes it impossible, on the packaging and accompanying documents per Regulation (EC) No 765/2008. A missing or incomplete mark can trigger a compliance investigation.

UK RoHS post-Brexit. For Great Britain (England, Scotland, Wales), the UK RoHS Regulations 2012 (as amended in 2020) transpose the EU restrictions into UK law, and the UKCA mark has been required since 2023, with successive deadline extensions; the CE mark continues to be recognised for a defined period. For Northern Ireland, the CE mark remains accepted under the Windsor Framework in force since 2024. The UK DoC should reference the applicable UK Statutory Instruments.

Other marketplaces. Wayfair EU, ManoMano, Otto.de, Cdiscount and La Redoute run similar vendor compliance programmes, relying on RoHS and CE Marking as the baseline and adding EN 71 for toys, the EN 60335 series for household appliances or EN 61558 for chargers.

Shipping from China direct to the EU. The importer of record, whether the Amazon EU seller (FBA), the distributor or retail buyer, or a designated authorised representative, is legally responsible for holding the DoC and technical documentation and answering market surveillance authorities. Under Regulation (EU) 2019/1020, an EU-based economic operator must be identifiable for the product. See the shipping from China to Amazon FBA guide and, for the packaging layer, the EU packaging regulation guide. The pre-shipment inspection guide explains the last physical checkpoint before the goods leave the factory.

The takeaway: the marketplace layer is not a duplicate of RoHS; it is a documentation infrastructure that assumes RoHS and CE Marking are met and demands the paperwork to prove it on demand. Importers who have organised the factory-side workflow can respond within hours; those who have not face delisting and cascading order cancellations across all EU marketplaces.

Common RoHS Non-Compliance Scenarios and How Market Surveillance Catches Them

EU Member State market surveillance authorities publish non-compliance notifications for EEE placed on the market through the RAPEX / Safety Gate portal maintained by the European Commission. Dozens of RoHS non-compliance notifications on EEE imported from China are published each month, providing a concrete picture of what fails at the border and post-market.

How surveillance works. Each Member State designates market surveillance authorities (the DGCCRF in France, the Länder authorities in Germany, and equivalents elsewhere). They can inspect products on the market, request the DoC and technical documentation from importers, sample products for laboratory testing, and enforce sanctions. The Safety Gate portal publishes notifications weekly; filtering by "chemical" and the relevant product category shows the current enforcement pattern.

Recurring patterns from Safety Gate 2024-2026:

• Cadmium above 0.01% in polymer housings of consumer electronics from China, mainly from recycled plastics.
• Lead above 0.1% in solder of low-cost PCBAs, leaded solder despite a lead-free declaration.
• DEHP above 0.1% in PVC insulation of chargers, headphones and USB cables.
• PBDE above 0.1% in flame-retarded plastics of LED bulbs and small appliances (recycled plastics).
• Hexavalent chromium above 0.1% in plated metal hardware.
• Incomplete DoC: missing reference to 2015/863, missing signature, missing product identification.
• Missing CE mark on product or packaging.
• A fake CE mark visually similar to the official European Conformity mark but not matching its specifications.

Sanctions range from withdrawal and recall of all units placed on the market, to administrative fines set by each Member State (typically thousands to several hundred thousand euros per violation, and several million for serious or repeat cases), possible criminal sanctions for wilful violations affecting health or safety, and flagging in customs systems that leads to systematic inspection of future imports.

US comparison. The US has no federal equivalent to RoHS for consumer electronics; state-level laws exist in California, New Jersey and New York at limited scope. Federal frameworks relevant to EEE chemistry are TSCA (including formaldehyde in composite wood under TSCA Title VI), CPSC-enforced CPSIA (lead and phthalates in children's products) and California's Prop 65 warning requirement. See the CPSC eFiling guide, the CPSIA compliance guide, the California Prop 65 warning guide and the TSCA Title VI and CARB Phase 2 formaldehyde compliance guide.

Frequently Asked Questions

What does RoHS compliant mean?

RoHS compliant means an electrical or electronic product placed on the EU market meets the restrictions of Directive 2011/65/EU (RoHS 2 recast) as amended by Commission Delegated Directive (EU) 2015/863 (RoHS 3), does not exceed the maximum concentration values of the 10 restricted substances listed in Annex II at the homogeneous material level, and is supported by a manufacturer's Declaration of Conformity and technical documentation kept for ten years after the last product is placed on the market.

What are the 10 restricted substances of RoHS 3?

The 10 restricted substances listed in Annex II of the RoHS Directive as amended by Commission Delegated Directive (EU) 2015/863 are: lead (Pb, 0.1%), mercury (Hg, 0.1%), cadmium (Cd, 0.01%), hexavalent chromium (Cr VI, 0.1%), polybrominated biphenyls (PBB, 0.1%), polybrominated diphenyl ethers (PBDE, 0.1%), bis(2-ethylhexyl) phthalate (DEHP, 0.1%), butyl benzyl phthalate (BBP, 0.1%), dibutyl phthalate (DBP, 0.1%), and diisobutyl phthalate (DIBP, 0.1%). The four phthalates were added by RoHS 3.

What is RoHS 3?

RoHS 3 is the industry shorthand for Commission Delegated Directive (EU) 2015/863 of 31 March 2015, which amended Annex II of the RoHS 2 recast Directive 2011/65/EU to add four phthalates (DEHP, BBP, DBP, DIBP) to the list of restricted substances. The restriction became effective on 22 July 2019 for most product categories, and on 22 July 2021 for category 8 medical devices and category 9 monitoring and control instruments.

Is RoHS compliance mandatory?

Yes. RoHS compliance is mandatory for any electrical or electronic equipment (EEE) placed on the market in the European Union or the European Economic Area, and by transposition into national law in the United Kingdom under the UK RoHS Regulations 2012 (as amended after Brexit). Compliance is demonstrated by the manufacturer through a self-declaration (Declaration of Conformity) supported by technical documentation. There is no mandatory third-party certification by a notified body for RoHS alone.

How do you test for RoHS compliance?

RoHS testing follows the IEC 62321 series of standards. X-ray fluorescence (XRF) is used as a rapid non-destructive screening method for lead, cadmium, mercury, chromium and bromine at the element level (IEC 62321-3-1). Confirmation testing uses ICP-OES for Pb, Cd, Hg (IEC 62321-4 and IEC 62321-5), colorimetric method for hexavalent chromium (IEC 62321-7-1 and 7-2), and GC-MS for PBB, PBDE and phthalates (IEC 62321-6 and IEC 62321-8).

How do I get RoHS certified?

There is no mandatory RoHS certification issued by a third party. Compliance is demonstrated by the manufacturer through a self-declaration procedure. In practice, most manufacturers commission an ISO/IEC 17025-accredited laboratory to test critical homogeneous materials against the RoHS limits and issue a test report. The manufacturer then drafts a Declaration of Conformity, assembles the technical documentation per EN IEC 63000:2018, and affixes the CE mark to the product.

What is the difference between RoHS and REACH?

RoHS (Directive 2011/65/EU as amended by 2015/863) restricts 10 named substances in electrical and electronic equipment (EEE) at the homogeneous material level. REACH (Regulation (EC) No 1907/2006) covers registration, evaluation, authorisation and restriction of chemicals across all articles, including electronics but not limited to EEE. REACH has a candidate list of more than 200 substances of very high concern (SVHC) which evolves twice a year. The two regimes are complementary and both apply to EEE.

Does RoHS apply to imports from China?

Yes. Any electrical or electronic equipment (EEE) imported into the European Union must be RoHS compliant regardless of where it is manufactured. The importer of record in the EU is legally responsible for ensuring the product meets RoHS restrictions, holds a Declaration of Conformity from the Chinese manufacturer, has the required technical documentation available for market surveillance authorities, and carries the CE mark if the product also falls under other CE Marking directives such as Low Voltage or EMC.

What are the 11 EEE categories under RoHS?

The 11 EEE categories listed in Annex I of Directive 2011/65/EU are: (1) large household appliances, (2) small household appliances, (3) IT and telecommunications equipment, (4) consumer equipment, (5) lighting equipment, (6) electrical and electronic tools, (7) toys, leisure and sports equipment, (8) medical devices, (9) monitoring and control instruments, (10) automatic dispensers, and (11) other EEE not covered under the previous categories (open-scope catch-all category added by RoHS 2 recast).

What is a homogeneous material under RoHS?

A homogeneous material under RoHS is a material of uniform composition throughout that cannot be mechanically disjointed into different materials. For example, a plastic housing is one homogeneous material, but a plated screw contains at least two (the base steel and the plating). The concentration limits in Annex II apply at the homogeneous material level, not at the product or assembly level. A single finished electronic product may contain dozens or hundreds of homogeneous materials.