This reference guide explains how sales, procurement, engineering, quality and compliance teams can review RoHS restrictions, exemptions, homogeneous materials and supporting records before placing electrical and electronic equipment (EEE) on the EU market. Exemptions can be amended, renewed or revoked. The guide reflects EU public materials checked on 21 August 2026; each SKU still requires a product-specific review against the applicable version.

1. Separate “RoHS compliance” into four questions

RoHS is not a standalone “green label” that can travel independently of the product facts. For each SKU, answer four questions:

  1. Is the product within scope? Check whether it is EEE within the categories in Annex I to Directive 2011/65/EU and whether the relevant Article 2, Article 4 or exclusion boundaries apply.
  2. Do materials exceed a restriction? The ten restricted substances in Annex II are assessed at homogeneous-material level. The commonly cited limits are 0.1% by weight for lead, mercury, hexavalent chromium, PBBs, PBDEs and the four phthalates, and 0.01% for cadmium. The applicable legal text and material facts control the assessment.
  3. Is a specific exemption actually needed? An exemption is a targeted exception for a material, component and use. It is not permission for an entire product to contain any restricted substance. The exemption number, conditions, material location and BOM revision must align.
  4. Do the records support the conclusion? Technical documentation, the EU Declaration of Conformity, supplier declarations and laboratory reports serve different purposes. A supplier CoC or an old report is not automatically the complete evidence package.

Homogeneous material is the critical review level. A cable should not be assessed only by averaging the complete cable: the conductor, plating and insulation may need separate identification according to what can be mechanically disassembled. The same reasoning applies to PCBs, plastics, coatings, adhesives and seals. A report’s cover page saying “RoHS” does not establish that the relevant materials were covered.

2. Do not copy an old sunset table: verify the number and the status

The original article mixed the subject matter and dates of exemptions 6(a)-I, 7(a)-I and 7(c)-I. Current EU amendment materials require these distinctions:

  • 6(a)-I: lead as an alloying element in steel for machining purposes, up to 0.35% by weight; the current amended text lists 30 June 2027 for all categories. Lead in copper alloys is 6(c), not 6(a)-I; 6(c) is also listed with a 30 June 2027 expiry.
  • 7(a)-I: lead in high-melting-temperature solders for specified internal interconnections in semiconductor assembly, with conditions concerning current, voltage or die size. It must not be generalized to every BGA, QFP or communications-device solder joint. Directive 2025/1802 lists 31 December 2027 for this entry.
  • 7(c)-I and 7(c)-II: 7(c)-I covers lead in specified glass or ceramic applications other than dielectric ceramic in capacitors. High-voltage dielectric ceramic capacitors are addressed by 7(c)-II, which the current amended text lists with a 31 December 2027 expiry. The voltage, material and use conditions still have to be checked for the part.

The date alone is not the complete answer. The European Commission explains that an existing exemption for which a renewal request was submitted on time remains valid until the Commission decides. An exemption for which no timely renewal request was submitted expires on the date in the Directive or relevant Annex. Therefore, it is inaccurate to state broadly that there is “no grace period,” and it is equally unsafe to treat a consultation or application as an automatic extension. Record the check date, category, official amendment or renewal status, and revisit the BOM when the status changes.

Article 4(4)(f) also provides a boundary for EEE that benefited from a specific exemption and was placed on the market before that exemption expired. Whether a product was “placed on the market” and who the relevant economic operator is depends on the transaction and supply-chain facts. “In transit,” “in an FBA warehouse” or a marketplace status should not be used as a substitute for that legal analysis.

3. What FMD, CoC, DoC and test reports each establish

Keep the records in layers instead of asking one document to prove everything:

  • FMD or material declaration: records the supplier’s declared materials, material levels, substance data and any claimed exemption. Check the supplier part number, homogeneous material, BOM revision, data date and responsible entity.
  • CoC: is a written statement from the supplier about its component or material. It may support the technical file, but it does not automatically prove that every finished-product material was independently tested or that the exemption conditions are met.
  • EU Declaration of Conformity: is issued by the manufacturer or other legally responsible entity under the applicable rules. The issuer, product identification, legislation, signature and revision must match the finished product and technical documentation; brand ownership alone does not determine every manufacturer role.
  • Laboratory report: review the model and revision, sampling information, homogeneous-material preparation, substances, methods, detection or quantification limits, results, laboratory competence/scope and authenticity checks. The analytical strategy should match the substance and material; there is no single mandatory “XRF + ICP + GC-MS” package that replaces product-specific judgment.

Create a cross-reference of supplier part number, internal item number, BOM revision and finished-product model/SKU. If the PCB, resin, cable, solder, ink or adhesive changes, assess whether homogeneous materials and risk have changed before deciding whether updated declarations, samples or testing are needed. The common statement “valid only for the samples received” is a real boundary, not proof that the report remains permanently valid for all production batches.

4. Six-step review checklist for EU sales

  1. Lock the legal version: record Directive 2011/65/EU, the relevant Annex II/III/IV entries, the latest amendments and the date checked.
  2. Map the product: build the BOM and homogeneous-material list, highlighting solder, metal alloys, glass/ceramic, plastics, coatings, cables and adhesives.
  3. Review each exemption line by line: record the number, material location, use conditions, EEE category, active/renewal status and replacement plan. Do not merge 6(c), 7(a)-I, 7(c)-I and 7(c)-II.
  4. Align the evidence: cross-check supplier FMD/CoC, laboratory reports, BOM revisions, finished-product models and the DoC by date and version; list missing items as open evidence gaps.
  5. Review the listing language: limit “RoHS compliant” or similar wording to a specific model and market supported by the product evidence. Do not use checkmark covers, certification badges or “platform approved” language that the records cannot prove.
  6. Set change triggers: reassess when a supplier, formulation, critical part, BOM revision, target market or exemption status changes instead of renewing reports only by a fixed number of months.

Boundary note: RoHS evidence preparation is not a certification result and does not replace UK RoHS, REACH, ecodesign, product safety, WEEE or marketplace-specific requirements. A marketplace may request documents, but its workflow should not be written as an automatic consequence of EU law.

Sources and ongoing verification

Public materials and exemption statuses may continue to change. Before shipment, re-check the applicable category, material, production/placing-on-market facts and the official text in force at that time.