Artifact GuideEU

EU RoHS Directive Technical Documentation and CE

RoHS technical documentation is the evidence file behind a finished EEE product's EU declaration of conformity and CE marking.

This guide helps separate EN IEC 63000 material-assessment evidence from declaration, marking, retention, importer, distributor, and authority-response duties.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

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

For RoHS, , the , and are related but not interchangeable. First confirm that the finished product is EEE within Directive 2011/65/EU and is not covered by an Article 2 exclusion. EN IEC 63000 supports the material, component, and EEE assessment record; the Directive assigns legal duties for drawing up documentation, running internal production control, signing the declaration, affixing CE marking, retaining records, and answering market-surveillance requests.

Section 1

Separate the evidence file from the declaration and mark

The RoHS evidence file should show why the EEE meets Article 4 restricted-substance requirements, including how each was assessed, the supplier evidence, exemptions if used, and any testing or assessment relied on.

Decision (EU) 2020/659 identifies EN IEC 63000:2018 as the harmonised standard for used to assess materials, components, and electrical and electronic equipment against hazardous-substance restrictions. That standard supports the technical documentation record; it is not itself the and it is not the act of affixing .

Under Article 7 of Directive 2011/65/EU, the manufacturer draws up the required , carries out internal production control under Module A of Decision No 768/2008/EC or has it carried out, then draws up the and affixes when compliance has been demonstrated.

Module A is manufacturer-controlled conformity assessment; RoHS does not generally require a notified body or third-party certificate. Using EN IEC 63000 is voluntary, but a harmonised standard whose reference is published in the Official Journal can support the Article 16 presumption of conformity. The binding duties and Annex II limits still come from the Directive and national implementing law.

  • Use EN IEC 63000 to structure the RoHS material-assessment file for materials, components, and finished EEE.
  • Use the to state that Article 4 requirements have been demonstrated and to follow the Annex VI model structure.
  • Use only after the applicable conformity assessment has been completed and before the finished EEE is placed on the market.
  • Keep the and EU declaration for 10 years after the EEE has been placed on the market.
Section 2

Build the RoHS technical documentation record

A useful RoHS file lets a reviewer trace the finished product back to material-level restrictions. Start with the exact product identity, category, role, market-placement date, BOM or component list, homogeneous-material assumptions, and the restricted substances in Annex II.

Then attach the evidence that supports each material or component decision. Depending on risk and supplier maturity, that may include supplier declarations, material declarations, exemption rationale, test reports, or IEC 62321-family test evidence. If a harmonised standard or technical specification changes, Article 7 requires manufacturers to take those changes into account for series production.

Do not treat as proof that the underlying RoHS file is complete or as an authority approval. The manufacturer uses the mark to indicate conformity with applicable Union harmonisation legislation that provides for CE marking; the is the inspectable record that explains the assessment path.

Apply Annex II at homogeneous-material level: 0.01% by weight for cadmium and 0.1% for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP. If an exemption is used, record the exact Annex III or IV wording, EEE category, application, validity status, affected BOM line, and evidence showing that the product facts fit the entry.

  • Record the finished EEE, type, batch, serial number, or other identification that connects the evidence to the product.
  • Map restricted-substance conclusions to homogeneous materials, not only to assemblies or supplier part numbers.
  • Keep exemption entries separate from general supplier declarations so expiry and scope can be reviewed.
  • Add a change-control trigger for design, supplier, material, harmonised-standard, or technical-specification changes.
Section 3

Assign manufacturer, importer, and distributor duties correctly

The manufacturer owns RoHS design-and-manufacture conformity, , internal production control, the , , series-production controls, non-conforming product records, corrective action, and authority responses.

Importers do not simply collect a supplier certificate. Before placing EEE from a third country on the Union market, they must ensure that the manufacturer carried out the appropriate conformity assessment, drew up , applied , supplied required documents, and met product-identification and contact-address duties. Importers must also keep a copy of the EU declaration for 10 years and ensure technical documentation can be made available on request.

Distributors act with due care when making EEE available. They verify , required documents in the relevant language, manufacturer and importer identification, and they must not make EEE available if they know or have reason to believe it is not in conformity with Article 4.

  • Treat private-label or materially modified EEE carefully: an importer or distributor can become subject to manufacturer obligations if it places EEE on the market under its own name or trademark or modifies EEE in a way that may affect compliance.
  • Do not let procurement use a declaration-only intake for imported EEE unless the importer has verified the required manufacturer steps and has a workable route for making the available to authorities on request.
  • Keep economic-operator traceability for 10 years so supplied-from and supplied-to links can be identified for market-surveillance authorities.
Section 4

Use a release checklist that authorities can audit

Before release, confirm that the evidence file, declaration, marking, labels, and operator records tell the same story. The product identity in the technical file should match the EU declaration, CE-marked finished product, packaging or accompanying documents, and importer/distributor records where applicable.

Article 13 requires the EU declaration to state that Article 4 requirements have been met, follow the Annex VI model structure, stay updated, and be translated into required Member State languages. Article 15 requires to be visible, legible, and indelible on the finished EEE or data plate, or on packaging and accompanying documents when product marking is not possible or warranted because of the nature of the EEE.

Use a release gate: do not ship CE-marked EEE until the RoHS supports the declaration, the operator role is clear, and the 10-year retention and authority-response path is assigned.

  • Confirm Article 4 restricted-substance compliance for the exact EEE being placed on the market.
  • Confirm the references EN IEC 63000 or another justified assessment route and keeps supporting evidence with the product file.
  • Confirm the EU declaration follows Annex VI content and is translated for the relevant market.
  • Confirm Annex VI includes a unique EEE identification, manufacturer or authorised-representative name and address, the manufacturer's sole-responsibility statement, traceable object description, the Directive 2011/65/EU conformity statement, applicable harmonised-standard or technical-specification references, additional information, and authorised signature details.
  • Confirm placement before market placement and document any packaging or accompanying-document marking decision.
  • Confirm who will respond to a competent national authority request and where the and EU declaration are retained.
Primary sources

References and citations

single-market-economy.ec.europa.eu
Referenced sections
  • Commission page identifying RoHS harmonised-standard publications and the Decision 2020/659 reference.
"Publications in the Official Journal"
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