EU RoHS Directive Supplier Declarations

Directive 2011/65/EU restricts listed substances in electrical and electronic equipment at homogeneous-material level. A supplier declaration helps only when it is specific enough to show which material, component, cable, spare part, finish, or assembly is being represented as compliant.

Request declarations that identify the supplier, part number, revision, covered RoHS substance list, claimed Annex III or Annex IV exemption, date, signatory, and evidence basis. Broad statements such as "RoHS compliant" are weak unless they can be traced to the actual BOM line and restriction being assessed.

The scope test belongs in the customer file even when the supplier provides the declaration. EEE depends on electric currents or electromagnetic fields for at least one intended function and is designed within the 1,000 V AC or 1,500 V DC limits. An Annex I category does not override an Article 2 exclusion, and a component for integration is not automatically subject to the same separate CE-marking and declaration steps as finished EEE.

Supplier evidence can feed a manufacturer's RoHS technical documentation, but it is not the finished-product EU declaration of conformity. Under Article 7, manufacturers must draw up the required technical documentation, carry out internal production control, draw up an EU declaration of conformity when compliance is demonstrated, and affix CE marking to the finished product.

Article 13 says the EU declaration of conformity states that Article 4 requirements have been met and that the manufacturer assumes responsibility by drawing it up. That responsibility should not be shifted to a supplier declaration, even when the supplier statement is current and useful.

The practical output is a declaration intake record that a product, quality, procurement, or regulatory reviewer can audit without reconstructing the project history. It should show what was requested, what was received, what it covers, what it does not cover, who accepted it, and what follow-up is required.

For RoHS, the intake record should also preserve the decision logic for homogeneous-material thresholds, exemptions, and technical-documentation evidence. If the supplier cites a test report or material declaration, keep the tested material, method reference, sample date, lab, and covered substances with the declaration.

Use an exemption status that distinguishes an active entry, a timely renewal still awaiting a Commission decision, an expired entry, a rejected or revoked entry in its 12-to-18-month transition, and a new request that has not been granted. A pending new request cannot support placing non-conforming EEE on the EU market.

A declaration should be refreshed when the evidence no longer matches the product or the legal assessment. Article 7 requires procedures so series production remains in conformity and requires changes in product design, characteristics, harmonised standards, or technical specifications to be taken into account.

Verification depth should follow the unresolved question. RoHS does not make a supplier statement automatically sufficient for any class of part. Current, item-specific supplier evidence may support a conclusion where it covers the relevant homogeneous materials, substances, revision, and exemption position; uncertain coatings, solder, plastics, flame retardants, plasticisers, exemption-sensitive applications, reused parts, or inconsistent documents may need material declarations, targeted testing, or supplier corrective action.

Keep screening and substance-specific analysis distinct. For example, an XRF result for total chromium cannot by itself establish hexavalent chromium concentration, and total bromine does not identify PBB or PBDE. Record what the test measures and how an inconclusive screen will be resolved.