Reopen the RoHS review when a supplier change can affect the substances, homogeneous materials, exemptions, traceability, or technical-documentation basis used for the finished EEE. The trigger is not limited to a new legal entity; a process, site, sub-tier, finish, coating, resin, solder, cable, or BOM revision can also change the evidence behind a RoHS conclusion.
The first decision is whether the changed item is part of finished EEE, a component supplied for integration, a separately placed-on-the-market EEE, a cable, or a spare part. The Commission FAQ explains that components used in finished EEE must meet the substance restrictions, but components for integration do not necessarily need their own RoHS CE marking or Declaration of Conformity when covered by the finished EEE context.
Also identify timing and inventory. Record the supplier's change-effective date, first changed lot or shipment, last known compliant lot, stock on hand, work in progress, products already placed on the market, service spares, and markets affected. A prospective supplier approval does not answer whether earlier or mixed inventory needs containment or a non-conformity assessment.