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FAQEU

RoHS FAQ Imported EEE

Under Article 9 of Directive 2011/65/EU, importers must place only compliant electrical and electronic equipment (EEE) on the Union market and must check the manufacturer's conformity work before market placement.

This page helps turn the RoHS duties into a practical evidence checklist for CE marking, , technical documentation access, importer identity, and nonconformity response.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections3 primary sources
Overview

Before placing imported EEE on the EU market, a RoHS should confirm that the manufacturer has completed the appropriate conformity assessment, drawn up technical documentation, affixed the CE marking, supplied the required documents, and met the RoHS manufacturer traceability duties. The importer must also show its own name or trade mark and contact address, keep a copy of the (DoC) for 10 years after placing the EEE on the market, ensure the technical documentation can be made available to authorities on request, and stop placement if it has reason to believe the EEE is not RoHS-compliant.

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4 of 4 questions
Question 1

What must importers check before placing EEE on the EU market under RoHS?

Article 9 of Directive 2011/65/EU makes the a gatekeeper for imported EEE. The importer must place only EEE that complies with RoHS on the Union market. occurs when the EEE is made available on the Union market for the first time, so the importer must complete the manufacturer's conformity check before that first supply.

The pre-placement check must go beyond a supplier questionnaire. Article 9 requires the to ensure that the manufacturer carried out the appropriate conformity assessment and drew up the technical documentation, that the EEE bears the CE marking and comes with the required documents, and that the manufacturer supplied the identification and address information required by Article 7.

  • Confirm the product is EEE in scope and is being placed on the EU market by the .
  • Check that the manufacturer carried out the appropriate conformity assessment and drew up RoHS technical documentation.
  • Check that the finished EEE bears the CE marking and is accompanied by the required documents.
  • Check that manufacturer identification and address information are present, and add the name, registered trade name or trade mark, and contact address on the EEE or, where that is not possible, on the packaging or accompanying document.
  • If there is reason to believe the EEE is not RoHS-compliant, do not place it on the market until it has been brought into conformity; inform the manufacturer and the market surveillance authorities.
  • If the places the EEE on the market under its own name or trade mark, or modifies it in a way that may affect compliance, Article 11 treats the importer as the manufacturer for RoHS purposes.

What must importers check before placing EEE on the EU market under RoHS?

Importers must ensure that the manufacturer completed the appropriate conformity assessment, drew up technical documentation, affixed CE marking, supplied the required documents, and provided the identity and address details required by Article 7. The must also add its own identity and contact address, keep the for 10 years after placing the EEE on the market, and ensure the technical documentation can be made available to authorities on request.

Can an rely only on a supplier's RoHS-compliant label?

No. A label or supplier statement is not enough by itself if it does not connect to the exact EEE placed on the EU market, the relevant model or batch, the manufacturer's , technical documentation availability, CE marking, and traceability information.

Question 2

Which evidence should an importer keep for imported EEE?

The must keep a copy of the for 10 years after placing the EEE on the market and must ensure the technical documentation can be made available to market surveillance authorities on request. That makes the import file an evidence index as much as a purchasing record.

A useful file links the exact product identity to the EU declaration, technical documentation access route, CE marking check, manufacturer and importer traceability markings, supplier material evidence, and any exemption or change-control assumptions used to support the RoHS conclusion.

  • Store the for the model or product family actually imported, and verify it references Directive 2011/65/EU where RoHS applies.
  • Record where the RoHS technical documentation can be obtained quickly if an authority asks for it; EN IEC 63000:2018 is the harmonised technical-documentation standard referenced in Commission Implementing Decision (EU) 2020/659. As an operational access check, record the manufacturer's document custodian, contact details, agreed retrieval process, and date of the latest retrieval check; escalate an unavailable file before first supply.
  • Keep evidence that the CE mark was present before market placement and that required accompanying documents were present in the needed language context.
  • Keep a register of non-compliant EEE and recalls, and document corrective action, withdrawal, recall, and authority notifications where relevant.
  • Tie supplier declarations, material declarations, test reports, and exemption claims to the exact EEE, component, material, model, batch, or revision they support.
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Question 3

What should stop the importer from placing the EEE on the market?

Article 9 is explicit: if an considers or has reason to believe that EEE is not in conformity with Article 4, the importer must not place it on the market until it has been brought into conformity. The importer must also inform the manufacturer and market surveillance authorities.

Use that rule as an escalation trigger. A missing or mismatched EU declaration, missing CE marking, unavailable technical documentation, unsupported exemption claim, product change, or credible restricted-substance concern should pause placement. A supplier-data gap needs case-specific review because Article 9's legal stop rule is triggered when the considers or has reason to believe the EEE is not in conformity with Article 4.

  • Escalate mismatches between the DoC, product label, model number, batch, shipment documents, or supplier evidence.
  • Escalate missing or manufacturer traceability information before goods are released to the EU market.
  • Escalate any indication that a may exceed a RoHS restriction or that an exemption claim no longer fits the application.
  • Document the final outcome as placed, corrected before placement, withdrawn, recalled, or blocked from market placement.
Question 4

How should the importer turn the check into a repeatable workflow?

Treat imported EEE review as a release gate tied to the exact product being placed on the EU market. The decision should be readable by procurement, logistics, quality, legal, and product teams without relying on undocumented supplier conversations.

Keep the record short and specific: identify the imported product, manufacturer and , DoC and technical-file evidence checked, supplier evidence supporting substance compliance, issues found, and the person who approved release or blocked placement.

  • Create one review record per product family, model, or shipment scope where the evidence is the same.
  • Map each imported EEE record to the DoC, technical-documentation access path, CE marking check, traceability marking check, supplier evidence, and exemption assumptions.
  • As an operational allocation, procurement follows up supplier records, quality or regulatory retrieves and reviews the technical file, logistics applies the recorded release or hold decision, and a named compliance owner coordinates authority responses and recall-register updates.
  • Reopen the record after design changes, supplier changes, material changes, new test results, exemption changes, or authority requests.
Primary sources

References and citations

Directive 2011/65/EU on restriction of hazardous substances in EEE
eur-lex.europa.eu5 citations
Referenced sections
  • Binding consolidated RoHS source for importer obligations, CE marking, EU declaration of conformity, substance restrictions, technical documentation access, traceability, and authority cooperation.
  • Binding consolidated RoHS source for importer obligations, CE marking, EU declaration of conformity, substance restrictions, and market-surveillance cooperation.
  • Binding consolidated RoHS source for importer retention, authority-response, recall-register, and conformity duties.
Show 2 more
  • Binding consolidated RoHS source for the Article 9 no-placement rule and corrective action duties.
  • Binding consolidated RoHS source for importer evidence, traceability, nonconformity, retention, and authority-response obligations.
"importers place only EEE that complies with this Directive"
More quoted passages
"for 10 years following the placing on the market"
"does not place the EEE on the market"
"provide it with all the information and documentation necessary"
European Commission RoHS 2 FAQ
environment.ec.europa.eu4 citations
Referenced sections
  • Commission guidance used for RoHS CE marking, declaration of conformity, technical documentation, component, and placing-on-the-market context; the guidance states it is not legally binding.
  • Commission guidance used for RoHS CE marking, declaration of conformity, technical-documentation, component, and placing-on-the-market context; the guidance states it is not legally binding.
  • Commission guidance for DoC, CE marking, technical documentation, and whole-product documentation scope.
Show 1 more
  • Commission guidance explaining that CE marking and DoC are RoHS procedural requirements and that compliance is assessed at placing on the market.
"binding interpretation of EU legislation is the exclusive competence of the Court of Justice"
More quoted passages
"The FAQ is considered a ‘living document’"
"The DoC should reference the product as placed on the market"
"procedural requirements under RoHS 2"
Commission Implementing Decision (EU) 2020/659 on EN IEC 63000
data.europa.eu3 citations
Referenced sections
  • Official source publishing EN IEC 63000:2018 as the harmonised standard for RoHS technical documentation.
  • Official source for the harmonised technical-documentation standard supporting RoHS conformity assessment.
"EN IEC 63000:2018"
More quoted passages
"technical documentation required for assessing materials"

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