FAQEU

RoHS FAQ cables and evidence

EU RoHS treats many electrical-current or electromagnetic-field transfer cables as EEE, but the evidence and CE marking answer changes depending on whether the cable is internal, supplied with EEE, sold separately, optical, or tied to excluded equipment.

This FAQ helps classify cable scope, separate internal-wire evidence from finished-cable obligations, and keep RoHS technical documentation aligned with the cable's actual market placement.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Questions
4

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Primary sources
5

Cited legal and guidance references.

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Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

are not all handled the same way under EU RoHS. The Directive's defined term covers cables rated below 250 V that connect EEE to an outlet or connect EEE to each other. Commission FAQ guidance discusses a broader set of cables that transfer electrical currents or electromagnetic fields. and permanently attached cables usually follow the host EEE; separately placed need their own RoHS evidence, CE marking, and EU declaration of conformity when the relevant RoHS obligations apply.

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4 of 4 questions
Question 1

Are cables within the scope of EU RoHS?

Directive 2011/65/EU defines as cables rated below 250 V that connect EEE to an electrical outlet or connect two or more EEE to each other. That definition should not be stretched to every product called a cable. Commission RoHS FAQ guidance separately treats cables used to transfer electrical currents or electromagnetic fields as EEE unless they specifically belong to EEE or a combination of EEE outside RoHS scope.

This means a cable scope decision should start with the cable's function and market placement. A power cord, HDMI cable, network cable, cable reel, or cable supplied with equipment may have different evidence and conformity-documentation consequences even when the same restricted-substance limits apply at material level.

  • Treat electrical-current and electromagnetic-field transfer as potentially in scope; document any exclusion by tying the cable to the excluded host EEE or excluded combination.
  • A passive optical cable with no electrical or electronic parts is outside the Commission FAQ's EEE interpretation. An active optical cable or another cable assembly with electrical or electronic functions needs its own EEE scope assessment.
  • Use the type and intended use of the cable to place it in a category: the FAQ identifies specialised SCART, HDMI, and network as examples in categories 3 or 4, while non-finished cable reels without plugs can fall in category 11.

Are covered by the EU RoHS Directive?

Many are covered. RoHS defines cables as cables rated below 250 V that connect EEE to an outlet or connect EEE to each other. Commission FAQ guidance separately says cables used to transfer electrical currents or electromagnetic fields are generally in scope from 3 January 2013, unless they specifically belong to EEE or a combination of EEE outside RoHS scope. Passive optical cables without electrical or electronic parts are outside that guidance; active cable assemblies need a separate EEE assessment.

Do all cable products need their own RoHS CE marking and EU declaration of conformity?

No. Internal wiring and permanently attached follow the host EEE and do not need an individual RoHS CE mark or DoC. sold together with or marketed for use with CE-marked EEE must meet the material restrictions but do not need their own RoHS CE mark or DoC if covered by the EEE's DoC. External cables placed on the market separately need their own RoHS DoC and CE marking when the RoHS obligations apply.

Citations
Question 2

Internal wires, attached cables, and external cables

The Commission FAQ draws a clear distinction between , permanently attached , supplied with EEE, and external cables sold separately. Internal wiring in in-scope EEE must meet the RoHS material restrictions like the rest of the equipment, but it is not treated as a separately CE-marked cable product.

that are sold together with, marketed for, or shipped for use with an EEE follow the technical requirements of that EEE. Separately placed external cables are treated differently because the cable itself is the product being placed on the market.

  • For , keep material-compliance evidence in the host EEE technical file rather than creating a separate RoHS DoC for the wire.
  • For permanently attached , such as typical lamp cables in the FAQ example, apply the same principle as internal wiring and document the host EEE coverage.
  • For detachable supplied with an EEE, show that the cable is covered by the EEE's RoHS DoC and that the EEE is CE marked.
  • For separately sold , prepare product-level RoHS evidence, EU declaration of conformity, and CE marking once the applicable RoHS date has passed.
Citations
European Commission RoHS 2 FAQ

Commission FAQ guidance distinguishing internal wires, attached cables, external cables supplied with EEE, and separately placed cables.

Question 3

What cable evidence should manufacturers keep?

Cable evidence should prove both the scope decision and the substance-compliance decision. For scope, keep the rated voltage, connection function, whether the cable transfers electrical current or electromagnetic fields, whether it is optical, whether it is internal or external, and whether it is supplied with or separately placed on the market from the host EEE.

For substance compliance, keep material-level evidence because RoHS maximum concentration values apply by homogeneous material. A cable record should therefore separate insulation, jacket, copper conductor, solder, plating, connectors, flame-retardant polymers, and any other separable material or component that affects the restricted-substance assessment.

  • Record the cable's intended use, host EEE relationship, product category, and whether the cable is covered by the host EEE DoC or needs its own DoC.
  • Keep supplier material declarations, BOM links, exemption references where used, test or screening rationale, and any lab reports needed for higher-risk cable materials.
  • Use EN IEC 63000 technical-documentation logic for the evidence package: define what was assessed, why the evidence is reliable, and how supplier or test evidence supports the RoHS declaration.
  • Review the evidence after supplier, material, connector, coating, flame retardant, plasticizer, or market-placement changes.
Citations
Recommended next step

Build the RoHS cable evidence record

Record the cable function, voltage, host-equipment relationship, market placement, material evidence, conformity documents, owner, and review triggers.

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Answer RoHS scope, timing, and interpretation questions with cited outputs.

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Question 4

Cable compliance mistakes to avoid

A useful cable record states how the cable is placed on the market. A generic supplier RoHS statement does not answer whether the cable is internal, attached, supplied with the EEE, sold separately, optical, tied to excluded equipment, or covered by the host product's DoC.

The other common gap is testing at the wrong level. RoHS limits are assessed at homogeneous-material level, so a whole-cable statement should still be traceable to material declarations, supplier evidence, exemptions, or risk-based tests for the separable materials that make up the cable.

  • Do not give a separately sold external cable only a host-equipment DoC; the Commission FAQ says separately placed need their own RoHS DoC and CE marking from the relevant date.
  • Do not assign a passive optical cable to RoHS only because it is called a cable. Check separately whether the assembly contains active electrical or electronic parts.
  • Do not treat internal wiring as a separate finished cable product; document material restriction compliance through the host EEE evidence file.
  • Do not rely on a single cable family declaration after insulation, jacket, connector, plating, solder, supplier, or plasticizer changes.
Citations
Primary sources

References and citations

European Commission RoHS 2 FAQ
environment.ec.europa.eu
Referenced sections
  • Commission FAQ guidance for cable-specific scope and conformity-documentation mistakes.
"External cables placed on the market separately"
IEC 63000:2016 technical documentation standard
webstore.iec.ch
Referenced sections
  • IEC source describing the technical documentation compiled to declare compliance with substance restrictions.
"declare compliance with the applicable substance restrictions"
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