RoHS FAQ cables and evidence

Directive 2011/65/EU defines cables as all cables with a rated voltage below 250 V that connect EEE to an electrical outlet or connect two or more EEE to each other. Commission RoHS FAQ guidance adds the practical scope rule: cables used to transfer electrical currents or electromagnetic fields are EEE, unless they specifically belong to EEE or a combination of EEE that is 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.

The Commission FAQ draws a clear distinction between internal wires, permanently attached cables, external cables 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.

External cables 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.

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.

The weak cable record is usually not missing a slogan; it is missing the market-placement fact pattern. 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.