Map the suspected infringement to a specific provision. Article 4 requires covered EEE, including relevant cables and spare parts, not to exceed the Annex II concentration value in any homogeneous material unless an applicable Annex III or IV exemption or transition covers that use. A finished-product average does not replace that material-level test.
Manufacturers must design and manufacture to Article 4, draw up technical documentation, carry out internal production control, issue an EU declaration of conformity after compliance is demonstrated, affix CE marking, keep the technical documentation and declaration for 10 years after placement, control series production, and respond to non-conformity. Drawing up the declaration makes the manufacturer responsible for the EEE's RoHS compliance.
Importers and distributors have their own pre-market checks, stop-sale duties, corrective-response duties, and authority-cooperation duties. An importer or distributor also becomes subject to the manufacturer's Article 7 obligations if it markets EEE under its own name or trademark, or modifies EEE already placed on the market in a way that may affect compliance.