A RoHS supplier declaration is supporting evidence for the manufacturer technical file. It should identify parts, homogeneous-material evidence, restricted-substance coverage, exemption claims, test records, and change triggers.
This guide helps collect supplier evidence without confusing it with the manufacturer EU Declaration of Conformity, CE marking, or Article 7 technical-documentation duties.
Use this RoHS template to turn a supplier statement into a traceable input for the finished-EEE technical file. Confirm product scope first, then collect item and revision identity, homogeneous-material and Annex II coverage, any Annex III or IV exemption, evidence references, limitations, approval, and change triggers. Directive 2011/65/EU keeps technical documentation, internal production control, the EU declaration of conformity, CE marking, series-production control, and 10-year retention with the manufacturer.
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Section 1
What the supplier declaration should and should not do
The template should ask suppliers for evidence that maps to the RoHS legal test: whether electrical and electronic equipment placed on the market contains restricted substances above the tolerated concentration values by weight in homogeneous materials. That means the useful unit is usually a part, material, coating, solder, plastic, cable, or subassembly with enough detail to connect the declaration to the product bill of materials.
Do not use a as a substitute for the manufacturer's EU Declaration of Conformity. Article 13 states that the EU Declaration of Conformity declares that Article 4 requirements have been met, and that by drawing it up the manufacturer assumes responsibility for compliance of the EEE with the Directive.
Before sending the form, record the customer's scope decision. EEE depends on electric currents or electromagnetic fields for at least one intended function and is designed within 1,000 V AC or 1,500 V DC. Identify the Annex I category, any Article 2 exclusion, whether the item is finished EEE or a component for integration, and which legal entity will act as manufacturer, importer, or distributor.
Copy-ready template text:
of RoHS evidence
Supplier legal name: [insert legal name]
Supplier address: [insert address]
Contact person: [insert name, title, email, phone]
Declaration date: [insert date]
Declaration version: [insert version]
Covered item(s): [supplier part number, customer part number, revision, description]
Manufacturing site(s): [insert site if relevant]
Product or BOM line supported: [insert product name or BOM line]
Legal basis reviewed: Directive 2011/65/EU, current consolidated version [insert date]
We declare that the covered item(s) listed above were assessed against the Annex II substance restrictions for lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP. For each homogeneous material and substance, record one status: at or below 0.1% by weight / at or below 0.01% by weight for cadmium / exemption relied on / above the applicable limit / unknown / not assessed. State the evidence basis and every material, variant, site, date, or process limitation.
Evidence supporting this declaration: [material declaration, full material disclosure, test report, IEC 62321 method reference, production control note, EN IEC 63000 assessment, or other supporting record].
Exemption claim, if any: [Annex III or Annex IV number, exact current wording, substance and homogeneous material, application, covered EEE category, legal status, expiry or renewal status, justification].
Change notice commitment: The supplier will notify the customer before any material, formulation, process, source, sub-tier supplier, manufacturing site, finish, or design change that may affect this evidence.
Responsible person: [name]
Title: [title]
Signature or approval method: [signature or approved system]
Date: [date]
Next review or change trigger: [insert trigger]
Identify the supplier legal name, address, contact, declaration date, covered part numbers, revisions, manufacturing sites if relevant, and the product or BOM line the evidence supports.
Require substance coverage against the current RoHS Annex II list, including lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP.
Ask whether the declaration covers homogeneous materials, a component, a cable, a spare part, or a finished EEE, because CE marking and DoC expectations differ by role and product status.
State that the declaration is supplier evidence for assessment and technical documentation, not the finished-product EU DoC unless the supplier is acting as the manufacturer for that finished EEE.
A useful is not just a one-line 'RoHS compliant' statement. It should make the evidence auditable by showing what was reviewed, which substances were covered, whether any exemption is claimed, and which documents support the statement.
For each covered item, ask the supplier to separate affirmative claims from evidence. A statement that a component complies is weaker than a statement tied to material declarations, composition data, relevant test reports, controlled production processes, or a documented EN IEC 63000 assessment.
Do not ask the supplier to certify facts outside its control. The supplier can state the evidence boundary for its item; the finished-EEE manufacturer must combine that input with the BOM, exemptions, technical documentation, internal production control, and other applicable Union product requirements.
Covered item: supplier part number, customer part number, revision, description, material family, and whether the declaration applies to all variants or only named versions.
Substance matrix: one row for each Annex II substance, with below the applicable homogeneous-material limit, exemption relied on, above the applicable limit, unknown, or not assessed as controlled answer choices, plus the evidence basis.
Evidence references: material declaration, full material disclosure where available, test report, IEC 62321 method reference where testing was used, production control note, or prior approved technical-documentation record.
Exemption fields: Annex III or Annex IV exemption number, exact application, expiry or review trigger if known from the cited exemption text, and supplier justification.
Signer fields: responsible person, title, signature or approval method, date, declaration version, and commitment to notify changes that may affect RoHS evidence.
Turn supplier declarations into RoHS technical-file evidence
This guide helps align procurement intake, supplier declarations, material evidence, exemption tracking, and EN IEC 63000 review notes before the manufacturer signs the EU Declaration of Conformity.
How to review supplier declarations before relying on them
Review supplier declarations as evidence quality, not as a checkbox. The declaration should be current for the part revision, cover the right legal scope, identify the evidence basis, and avoid vague claims that cannot be traced to materials, tests, or controlled processes.
Article 16 supports a presumption of conformity for materials, components, and EEE when tests and measurements demonstrate Article 4 compliance or when assessment follows harmonised standards whose references are published in the Official Journal. A can point to that evidence, but the manufacturer still needs to decide whether it is enough for the finished-EEE technical file.
Check the date logic. The four phthalates applied from 22 July 2019 for most EEE and from 22 July 2021 for medical devices and monitoring and control instruments, subject to specified cable, spare-part, and toy carve-outs. An older six-substance form may still describe the evidence available at that time, but it does not support a current ten-substance claim without an updated assessment.
Reject or escalate declarations that say only 'RoHS compliant' with no part number, revision, substance coverage, exemption basis, date, or signer.
Check that phthalates are included where the declaration claims current Annex II coverage; older supplier forms may only cover the original six RoHS substance groups.
Treat blanket declarations, distributor certificates, and website statements as lower-confidence evidence unless they map clearly to the purchased part and revision.
Escalate for targeted testing or deeper supplier documentation when the material risk is high, the source is stale, the supplier changed, the process changed, or an exemption claim is central to the conclusion.
Outputs for procurement, quality, and the technical file
The template should produce a record that procurement can request, quality can audit, engineering can trace to a BOM revision, and regulatory teams can cite in the technical documentation. Keep the together with the independent review decision so the file shows why the evidence was accepted, rejected, or escalated.
The manufacturer file should then connect supplier inputs to the finished-product conclusion: Article 4 scope, Annex II substances, any exemption reliance, EN IEC 63000 assessment, selected test reports, EU Declaration of Conformity, CE marking decision, and the 10-year retention period after the EEE is placed on the market.
Create an acceptance status for each : accepted, accepted with limits, rejected, expired, needs supplier clarification, or needs testing.
Record the decision owner, review date, affected product or BOM revision, evidence limitations, and next review trigger.
Attach supplier declarations to change-control workflows for material changes, part substitutions, supplier changes, manufacturing-site changes, and changes to harmonised standards or legal requirements.
Keep the declaration near the technical-documentation index, not as an isolated procurement file that cannot be connected to the EU DoC.
Binding source for Article 7 obligations to keep technical documentation and the EU Declaration of Conformity for 10 years and to account for design, characteristic, standard, and specification changes.
"keep the technical documentation and the EU declaration of conformity"
Commission FAQ distinguishes component substance restrictions from separate CE marking or Declaration of Conformity requirements for components used in finished EEE.
IEC publisher page describing IEC 63000 as specifying the technical documentation a manufacturer compiles to declare compliance with applicable substance restrictions.