Artifact GuideEU

EU RoHS Directive Supplier Declarations and Verification

RoHS supplier evidence helps manufacturers, importers, and distributors check restricted-substance compliance, but it does not supersede the manufacturer's technical documentation, EU declaration of conformity, or CE marking responsibilities.

This page helps decide what to request from suppliers, when to verify it with standards or testing, and how to keep the evidence useful for release reviews and authority requests.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
9

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

A under EU RoHS is supporting evidence, not a shortcut to conformity. First confirm that the product is electrical and electronic equipment (EEE) within Directive 2011/65/EU and is not covered by an Article 2 exclusion. Then link each declaration to the exact material, component, assembly, supplier, Annex II substance, Annex III or IV exemption, test or assessment method, and economic-operator duty it supports.

Section 1

What a RoHS supplier declaration can and cannot prove

A can help document whether materials, components, or assemblies are represented as meeting RoHS substance restrictions. It is strongest when it identifies the supplied item, applicable restricted substances, any claimed exemption, revision or date, supplier contact, and the evidence basis behind the declaration.

Do not treat that declaration as the manufacturer's EU declaration of conformity. Under Directive 2011/65/EU, manufacturers must design and manufacture EEE according to Article 4, draw up technical documentation, use the internal production control procedure, issue the EU declaration of conformity when compliance is demonstrated, and affix CE marking to the finished product.

Scope comes first. EEE depends on electric currents or electromagnetic fields for at least one intended function and is designed for no more than 1,000 V AC or 1,500 V DC. Article 2 excludes specified equipment, including equipment for military or space use, means of transport other than non-type-approved electric two-wheel vehicles, large-scale stationary industrial tools, large-scale fixed installations, certain non-road mobile machinery, active implantable medical devices, qualifying photovoltaic panels, and custom-built business-to-business research equipment. Record the exact basis before asking a supplier to declare RoHS status.

  • Keep supplier evidence mapped to the exact part number, drawing revision, BOM line, material, finish, cable, spare part, or assembly that uses it.
  • Separate supplier statements from the finished-product EU declaration of conformity required by Annex VI.
  • Flag any that lacks product identification, substance coverage, exemption basis, date, signatory, or supporting test or assessment reference.
  • If your company imports, distributes, private-labels, or modifies EEE, record the role-specific duty instead of assuming the supplier's statement is enough.
  • Distinguish a component for integration from finished EEE placed on the market. The component must allow the finished EEE to meet the substance restrictions, but Commission guidance does not require a separate RoHS CE mark or EU declaration for every component used only in the finished-product context.
Section 2

Build the supplier evidence file before product release

Start with the finished EEE and work downward into the BOM. The RoHS restriction applies at homogeneous-material level, so declarations should be granular enough to support the materials, components, and assemblies that make up the product, not just a broad product-family promise.

For each supplier input, record whether it is a material declaration, test report, exemption statement, certificate-like statement, or contractual representation. Then decide whether the evidence is enough for the product's risk profile or whether the item needs additional review against harmonised standards, technical specifications, or targeted testing.

Apply the concentration values to each homogeneous material: 0.01% by weight for cadmium and 0.1% for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP. Do not average a high-substance coating, solder, or plastic against the rest of an assembly. A matching Annex III or IV exemption changes the conclusion only for the substance, application, category, wording, and validity conditions it covers.

  • List all RoHS Annex II substances covered by the declaration, including the phthalates added by Commission Delegated Directive (EU) 2015/863.
  • Record the maximum concentration basis at homogeneous-material level instead of averaging across a component or assembly.
  • Connect each claimed Annex III or Annex IV exemption to the precise application and expiry or renewal monitoring process.
  • Keep the supplier's declaration date, product identifiers, revision scope, test method references, and contact details with the technical file.
  • Mark evidence that is too broad, expired, inconsistent with the BOM, or unsupported by a test or assessment path for follow-up.
Recommended next step

Turn supplier RoHS evidence into a reviewable technical file

Keep supplier declarations, material evidence, exemption checks, technical documentation, EU DoC responsibilities, and role-specific reviews connected.

Section 3

Choose the verification depth for each supplied item

Verification is a documented judgment about evidence quality. RoHS does not prescribe one evidence type for every BOM line. A manufacturer may rely on current, item-specific supplier and material information where it resolves the relevant substance and exemption questions; gaps, contradictions, or higher-risk materials may call for test reports, disassembly or screening, supplier corrective action, or substitution review.

EN IEC 63000 is the harmonised RoHS technical-documentation standard referenced by the Commission. It supports an assessment approach for materials, components, and EEE; it should not be reduced to a request for a one-page supplier letter.

Testing also needs a defined question. XRF screening can identify total chromium or total bromine, but those elemental results do not by themselves establish hexavalent chromium, PBB, or PBDE concentrations. Use the relevant substance-specific IEC 62321 method when screening cannot resolve the regulated form.

  • Use supplier declarations as one evidence type inside the technical documentation, not as the only control for every BOM line.
  • Escalate evidence depth when a part contains solder, plating, pigments, plasticisers, flame retardants, complex electronics, reused components, or an exemption-sensitive use.
  • Prefer current material-declaration formats and supplier data structures where available, but check whether the standard or database version being cited is still current.
  • Keep test reports tied to sample preparation, screened material, method, date, lab, and tested substance set so future reviewers can understand what was actually verified.
Section 4

Keep role-specific RoHS duties separate

Supplier verification should answer a practical question: what does this evidence let our company responsibly conclude for our role? The answer is different for a component buyer, finished-product manufacturer, importer, distributor, authorised representative, or private-label seller.

Importers must check that the manufacturer has carried out the conformity assessment, drawn up technical documentation, applied CE marking, and supplied required documents before placing EEE on the Union market. Distributors must act with due care, including verifying CE marking and required accompanying documents. If an importer or distributor places EEE on the market under its own name or modifies it in a way that may affect compliance, manufacturer obligations apply.

  • Manufacturer file: supplier evidence supports Article 7 technical documentation, internal production control, EU DoC, CE marking, change control, and 10-year retention.
  • Importer file: keep a copy of the EU declaration of conformity for 10 years and ensure technical documentation can be made available on request.
  • Distributor file: keep proof that CE marking, required documents, manufacturer identification, and importer identification were checked before making the EEE available.
  • Private-label or modification file: treat the activity as a potential manufacturer-duty trigger and escalate before release.
Section 5

Refresh supplier declarations when evidence goes stale

A is not evergreen just because the part number has not changed. RoHS technical documentation must account for changes in product design, characteristics, harmonised standards, and technical specifications used to declare conformity.

Refresh the evidence when the supplier changes materials, finishes, manufacturing site, sub-supplier, formulation, exemption claim, test method, or declaration format. Also reopen the file when RoHS restricted substances, exemptions, harmonised-standard references, or market-surveillance questions change.

Set the next review from the evidence, not from an arbitrary annual cycle alone. Review before an exemption deadline, after a timely renewal application or Commission decision, when an old form omits the four phthalates that applied from 22 July 2019 for most EEE and from 22 July 2021 for medical devices and monitoring and control instruments, or whenever the supplied configuration no longer matches the accepted declaration.

  • Add renewal dates for declarations that support exemptions or high-risk materials.
  • Use change-control gates so engineering, procurement, quality, and regulatory teams do not accept altered parts on stale RoHS evidence.
  • Keep a non-conforming EEE and recall register where required by role, and connect supplier corrective actions to affected products.
  • When an authority asks for proof, provide the technical documentation path rather than a bundle of unreviewed supplier PDFs.
Primary sources

References and citations

single-market-economy.ec.europa.eu
Referenced sections
  • Commission source for RoHS harmonised-standard references and Official Journal context.
"Restriction of the use of certain hazardous substances"
webstore.iec.ch
Referenced sections
  • IEC publisher source for XRF screening of lead, mercury, cadmium, total chromium, and total bromine; the method screens elements rather than identifying every regulated chemical form.
"total chromium and total bromine"
webstore.iec.ch
Referenced sections
  • IEC publisher source for substance-specific determination of PBB and PBDE in polymers.
"Polybrominated biphenyls and polybrominated diphenyl ethers in polymers"
webstore.iec.ch
Referenced sections
  • IEC source describing the technical documentation standard for assessing electrical and electronic products against restricted-substance requirements.
"Technical documentation for the assessment"
Related guides

Explore more topics

Are cables in scope of EU RoHS? Cable evidence, CE marking, and DoC FAQ
EU RoHS cable FAQ covering when cables are EEE, how internal and external cables are treated, when separate CE marking and a DoC are needed, and what evidence to keep.
Do Components Need EU RoHS Compliance? | RoHS FAQ
RoHS FAQ for components in electrical and electronic equipment: substance restrictions, homogeneous materials, CE marking, technical files, exemptions, and supplier evidence.
EN IEC 63000 RoHS Technical Documentation
Build EN IEC 63000:2018 technical documentation for EU RoHS with manufacturer duties, evidence selection, harmonised-standard context, and file maintenance.
EU RoHS Annex III and IV exemptions guide
How to use, renew, or challenge EU RoHS Annex III and Annex IV exemptions, with Article 5 criteria, timing rules, and evidence requirements.
EU RoHS Applicability Test for EEE Scope
Decide whether EU RoHS applies to electrical and electronic equipment, cables, spare parts, exclusions, exemptions, CE marking, and evidence records.
EU RoHS CE Marking and Declaration of Conformity
Understand RoHS CE marking, the EU Declaration of Conformity, EN IEC 63000 technical documentation, and importer or distributor checks.
EU RoHS compliance checklist for EEE
Checklist for EU RoHS scope, restricted substances, homogeneous materials, exemptions, CE marking, technical documentation, and supplier evidence.
EU RoHS Compliance Guide for EEE
Practical EU RoHS compliance guide for electrical and electronic equipment: scope, restricted substances, exemptions, CE marking, technical documentation, and supplier evidence.
EU RoHS Deadlines and Compliance Calendar
Build a RoHS calendar for scope phase-ins, phthalate dates, exemption renewals, spare-part cutoffs, EN IEC 63000 evidence, CE files, and review triggers.
EU RoHS Declarations vs Lab Tests FAQ
When supplier declarations can support EU RoHS technical documentation, when IEC 62321 lab testing is stronger evidence, and how to document the decision.
EU RoHS Directive FAQ: scope, substances, CE marking
Practical EU RoHS Directive FAQ covering EEE scope, Annex II substance limits, cables, spare parts, technical documentation, CE marking, and exemptions.
EU RoHS EEE Categories and Open Scope
Map products to EU RoHS EEE categories, category 11 open scope, Article 2 exclusions, cables, spare parts, and evidence needed for RoHS scope decisions.
EU RoHS for medical devices and monitoring equipment
RoHS category 8 and 9 guide covering application dates, Annex IV exemptions, phthalates, spare parts, CE marking, declarations, and technical documentation.
EU RoHS penalties and fines: Member State sanctions
Understand EU RoHS penalty exposure, national sanctions, the absence of one EU-wide fine table, corrective actions, recalls, and evidence records.
EU RoHS Phthalates: DEHP, BBP, DBP, DIBP
Apply RoHS rules for DEHP, BBP, DBP, and DIBP, including 0.1% homogeneous-material limits, 2019 and 2021 dates, exemptions, evidence, and testing.
EU RoHS requirements for EEE, substances, and CE evidence
Practical EU RoHS requirements guide covering EEE scope, Annex II substance limits, exemptions, technical documentation, EU declaration of conformity, CE marking, and operator evidence.
EU RoHS Restricted Substances and Thresholds | Annex II Limits
EU RoHS Annex II restricted substances and maximum concentration values by weight in homogeneous materials, including cadmium's 0.01% limit and the 0.1% limits for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP.
EU RoHS Spare Parts: Repair and Reuse
Apply RoHS Article 4 to repair parts and reused recovered parts, including closed-loop conditions, phthalate carve-outs, CE evidence, and cutoff dates.
EU RoHS test plan selection workflow
Choose RoHS supplier evidence, EN IEC 63000 technical documentation, and IEC 62321 testing without over-testing or under-documenting restricted substances.
EU RoHS Timeline: Scope, Phthalates, Exemptions and Evidence
Understand which EU RoHS dates changed product scope or substance duties, which dates are historical, and which exemption, spare-part, and evidence deadlines still require action.
How should RoHS lead, mercury, and cadmium exemptions be documented? | RoHS FAQ
RoHS FAQ on documenting lead, mercury, and cadmium exemptions with Annex III or IV entries, material-level limits, expiry status, supplier evidence, and technical documentation.
RoHS BOM evidence intake workflow
Build a RoHS BOM evidence intake process for EEE: map parts to homogeneous materials, collect supplier declarations, handle exemptions, and feed EN IEC 63000 technical documentation.
RoHS exemption register workflow: expiry, renewal, evidence
Build a RoHS exemption register that tracks Annex III and IV entries, product scope, expiry dates, renewal status, evidence owners, and Commission source links.
RoHS exemptions tracker guide: fields, evidence, gates
Build a RoHS exemptions tracker for Annex III and IV claims, renewal timing, supplier evidence, EN IEC 63000 documentation, and release decisions.
RoHS Exemptions Tracking Register
Track EU RoHS Annex III and IV exemptions by material, component, category, expiry date, renewal status, Article 5 rationale, and evidence record.
RoHS Homogeneous Material Definition and Limits
Plain-English EU RoHS FAQ on homogeneous materials, Annex II thresholds, coatings, cables, assemblies, and evidence needed for material-level RoHS decisions.
RoHS Homogeneous Material Thresholds
EU RoHS guide to homogeneous material thresholds: 0.1% limits, the 0.01% cadmium limit, material splitting, coatings, samples, exemptions, and technical evidence.
RoHS importer checks for imported EEE before EU market placement
Importer-focused RoHS FAQ covering CE marking, EU declaration of conformity, technical documentation availability, importer identity, nonconformity handling, and 10-year DoC retention.
RoHS Risk-Based Testing Guide
Choose proportionate EU RoHS verification using supplier evidence, EN IEC 63000 documentation, IEC 62321 methods, and product-specific risk decisions.
RoHS Supplier Change Control Workflow
Control EU RoHS risk after part substitutions or material changes by reassessing supplier declarations, test needs, exemptions, and technical-file updates.
RoHS Supplier Declaration Template
Use a structured EU RoHS supplier declaration to collect material evidence, exemption claims, test records, and EN IEC 63000 technical-file inputs.
RoHS Supplier Declarations Guide
Use RoHS supplier declarations as supporting evidence for BOM, material, exemption, and technical-file reviews without replacing manufacturer EU DoC or CE duties.
RoHS technical documentation, EU DoC and CE marking
Connect RoHS technical documentation and EN IEC 63000 evidence to the EU declaration of conformity, CE marking, and economic-operator duties.
RoHS vs Batteries Regulation scope comparison
RoHS-focused comparison explaining when RoHS applies to EEE, why batteries sit outside RoHS, and what evidence should not be reused without separate battery-law support.
RoHS vs LVD/EMC CE evidence: what belongs in the RoHS file
Compare RoHS substance evidence with separate LVD and EMC CE evidence streams across scope, technical files, declarations, CE marking, exemptions, and supplier records.
RoHS vs POPs for EEE substance compliance
Compare EU RoHS and POPs obligations for electrical and electronic equipment: scope, substances, evidence, CE files, exemptions, waste overlap, and cited decision rules.
RoHS vs REACH for electronics: scope, evidence, overlap
Compare EU RoHS and REACH for electrical and electronic equipment: scope, restricted substances, evidence, CE marking, exemptions, and overlap decisions.
RoHS vs WEEE: EU electronics compliance comparison
Compare EU RoHS restricted-substance duties with WEEE end-of-life recycling obligations, with RoHS scope, evidence, CE marking, exemptions, and cited decision points.
RoHS, REACH, POPs, and batteries overlap
Separate RoHS restrictions and evidence from REACH, POPs, Batteries Regulation, waste, and adjacent technical-file workstreams for the same product.
What do the 0.1% and 0.01% substance limits mean under EU RoHS? | RoHS FAQ
RoHS FAQ explaining why most Annex II substances use a 0.1% homogeneous-material limit while cadmium uses 0.01%.
What should teams do before a RoHS exemption expires? | RoHS FAQ
How to handle EU RoHS exemption expiry: confirm the Annex entry, renewal deadline, pending-decision status, fallback plan, and technical-file evidence.
When can RoHS spare parts use transition rules? | RoHS FAQ
EU RoHS FAQ on spare parts, repair parts, reused parts, closed-loop B2B reuse, legacy EEE cutoffs, Annex III and IV exemptions, and evidence to keep.
Which EEE is in scope under EU RoHS? | RoHS FAQ
EU RoHS scope FAQ explaining when a product is electrical and electronic equipment, which Article 2 exclusions to check, and what evidence to keep.