EU RoHS Directive supplier declaration template

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 (BOM).

Do not use a supplier declaration as a substitute for the manufacturer's EU declaration of conformity (DoC). 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: Supplier declaration 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 bill of materials (BOM) line supported: [insert product name or BOM line] Legal basis reviewed: Directive 2011/65/EU, current consolidated version [insert date] For the covered item(s) listed above, we report the assessment status and evidence for 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 the applicable limit (0.01% by weight for cadmium; 0.1% by weight for each other listed substance) / exemption relied on / above the applicable limit / unknown / not assessed. A homogeneous material is one material of uniform composition throughout, or a combination that cannot be separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding, or abrasion. 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]

A useful supplier declaration identifies what was reviewed, which substances were covered, any claimed exemption, and the supporting documents.

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.

Assess the quality of each supplier declaration. 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 supplier declaration 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.

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 supplier declaration 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.