RoHS workflowEvidence and testing

EU RoHS test-plan selection workflow

Select RoHS evidence by first confirming EEE scope, homogeneous-material risk, restricted substances, exemptions, and economic-operator role before deciding whether supplier documentation is enough or analytical testing is needed.

Use for the technical-documentation file and IEC 62321 parts for substance-specific sample preparation, screening, and analytical test methods.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

A RoHS test plan should start with product scope, economic-operator role, homogeneous-material risk, Annex II limits, and any Annex III or IV exemption. Use to document the evidence decision, then select the relevant IEC 62321 sample-preparation, screening, or analytical method only when supplier data, prior evidence, or the unresolved risk makes testing necessary. The manufacturer still owns internal production control, the , CE marking, and the finished-EEE conclusion.

Section 1

Start with RoHS scope before choosing tests

Confirm that the product is electrical or electronic equipment in one of the Annex I categories, including category 11 for other EEE not covered by earlier categories. Then map the bill of materials to homogeneous materials, because Annex II concentration limits are stated at homogeneous-material level rather than finished-product level.

Record the operator role before assigning evidence tasks. Manufacturers carry the core duty to draw up technical documentation, perform internal production control, issue the , and affix CE marking. Importers and distributors also have checks and escalation duties, and an importer or distributor can be treated as the manufacturer if it places EEE on the market under its own name or modifies EEE in a way that may affect compliance.

Decide scope before testing. Apply the EEE definition, 1,000 V AC and 1,500 V DC design limits, Annex I category, and Article 2 exclusions. Equipment necessary to protect Member States' essential security interests, equipment designed to be sent into space, qualifying transport, large-scale tools or fixed installations, certain non-road mobile machinery, active implantable medical devices, qualifying photovoltaic panels, and equipment specifically designed solely for research and development and made available only business-to-business require documented scope facts, not a lab result.

  • Capture product category, market route, economic operator, BOM level, homogeneous-material breakdown, and any claimed Annex III or Annex IV exemption.
  • Screen every material family against Annex II: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP.
  • Use the RoHS limits as decision criteria: 0.1% by weight for most Annex II substances and 0.01% by weight for cadmium, each in homogeneous materials.
  • Do not select a test method until the material, restricted substance, supplier evidence, and exemption position are identified.
  • Choose one preliminary outcome per material: documentation sufficient, exemption fit confirmed, screen needed, substance-specific analysis needed, supplier clarification needed, substitute material needed, or release blocked.
Section 2

Use EN IEC 63000 for documentation, then IEC 62321 for testing

:2018 is the harmonised standard identified by Commission Implementing Decision (EU) 2020/659 for technical documentation supporting RoHS assessment. It is not itself a laboratory test method; it describes the technical-documentation approach used to assess materials, components, and EEE against restricted-substance requirements.

Use IEC 62321 parts when the selected evidence path calls for sample preparation, screening, or substance-specific analysis. IEC 62321-2 covers disassembly, disjointment, and mechanical sample preparation; IEC 62321-3-1:2026 covers that includes lead, mercury, cadmium, total chromium, and total bromine; IEC 62321-6 covers PBB and PBDE in polymers; IEC 62321-7-1 and 7-2 address hexavalent chromium in metal coatings and in polymers or electronics; IEC 62321-8 covers phthalates in polymers.

Treat XRF as screening for the elements it measures. A total-chromium result does not by itself establish the amount of hexavalent chromium, and total bromine does not identify PBB or PBDE. Define how an inconclusive or elevated screen will move to the substance-specific IEC 62321 method before sampling begins.

Write the decision rule before sending samples. Name the , regulated substance, applicable limit or exemption, sample-preparation method, screening or analytical method, laboratory, reporting units, measurement uncertainty, and pass, fail, or inconclusive branch. Do not turn a result close to a legal limit into a pass unless the chosen method and decision rule support that conclusion.

  • Documentation path: supplier declarations, material declarations, BOM evidence, exemption evidence, previous test reports, risk assessment, change records, and the technical-documentation file.
  • Screening path: XRF or other screening can help triage material risk, but elemental screening results need clear pass, fail, or inconclusive handling and cannot substitute for substance-specific analysis where speciation is required.
  • Analytical path: choose the IEC 62321 part that matches the material and substance, then record sample identity, homogeneous-material rationale, lab report, and acceptance decision.
  • Escalation path: test when supplier evidence is missing, stale, inconsistent with the material, affected by a material or supplier change, or insufficient to support the .
Section 3

Outputs the RoHS test-plan decision should produce

A useful RoHS test-plan decision leaves a reviewer with more than a list of lab tests. It should show why each material was cleared by supplier evidence, documented under , tested under an IEC 62321 method, covered by an exemption, or escalated because the evidence was not strong enough.

Keep the file usable for release gates and authority questions. Directive 2011/65/EU expects the to state that Article 4 requirements have been demonstrated, and the manufacturer assumes responsibility by drawing up that declaration.

  • A scoped BOM or material matrix with the RoHS category, homogeneous-material split, restricted substances of concern, and supplier evidence status.
  • A test-plan table that links each selected test to material, substance, IEC 62321 part, sample ID, lab report, result, and decision.
  • An technical-documentation index with supplier declarations, material declarations, test reports, exemption evidence, , CE marking record, and change-control triggers.
  • A decision log for unsupported claims, inconclusive screening, expired or product-mismatched supplier declarations, exemption assumptions, and retest triggers after material or supplier changes.
  • A sampling record that links each specimen to the received part, supplier, lot, revision, disassembly step, , photograph or location, preparation method, chain of custody, and remaining sample.
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Primary sources

References and citations

data.europa.eu3 citations
Referenced sections
  • Official source publishing EN IEC 63000:2018 as the RoHS harmonised standard for technical documentation.
  • Official source publishing EN IEC 63000:2018 as the harmonised standard for RoHS technical documentation.
  • Official source for the RoHS harmonised technical-documentation standard and its presumption-of-conformity context.
"technical documentation required for assessing materials"
More quoted passages
"Compliance with a harmonised standard confers a presumption"
eur-lex.europa.eu3 citations
Referenced sections
  • Consolidated RoHS source for scope, homogeneous-material definition, restricted-substance limits, exemptions, technical documentation, EU declaration of conformity, CE marking, and economic-operator duties. Consolidations are documentation tools; the Official Journal acts are the authentic legal texts.
  • Consolidated RoHS source for scope, homogeneous-material definition, Annex I categories, Annex II substance limits, exemptions, and economic-operator duties.
  • Consolidated source for manufacturer obligations, technical documentation, EU declaration of conformity, CE marking, and presumption of conformity provisions.
"maximum concentration values tolerated by weight in homogeneous materials"
More quoted passages
"draw up an EU declaration of conformity"
eur-lex.europa.eu2 citations
Referenced sections
  • General EU product-law guidance for economic operator roles, conformity assessment, declarations, CE marking, and importer documentation access.
  • General EU product-law guidance for manufacturer responsibility, technical documentation, declarations, CE marking, and importer documentation access.
"The manufacturer is responsible for the conformity assessment"
webstore.iec.ch2 citations
Referenced sections
  • IEC publisher page for disassembly, disjointment, and mechanical sample preparation before analytical testing.
  • IEC publisher page for disassembly, disjointment, and mechanical sample preparation before substance testing.
"Disassembly, disjointment and mechanical sample preparation"
webstore.iec.ch2 citations
Referenced sections
  • IEC publisher page for XRF screening of lead, mercury, cadmium, total chromium, and total bromine.
  • IEC publisher page for XRF screening of lead, mercury, cadmium, total chromium, and total bromine in uniform materials.
"X-ray fluorescence spectrometry"
webstore.iec.ch2 citations
Referenced sections
  • IEC publisher page for PBB and PBDE determination in polymers.
  • IEC publisher page for PBB and PBDE determination in polymers of electrotechnical products.
"Polybrominated biphenyls and polybrominated diphenyl ethers"
More quoted passages
"Polybrominated biphenyls and polybrominated diphenyl ethers in polymers"
webstore.iec.ch2 citations
Referenced sections
  • IEC publisher page for qualitative hexavalent chromium determination in corrosion-protected metal coatings.
  • IEC publisher page for qualitative determination of hexavalent chromium in corrosion-protected coatings on metals.
"presence of hexavalent chromium"
More quoted passages
"corrosion-protected coatings on metals"
webstore.iec.ch2 citations
Referenced sections
  • IEC publisher page for quantitative hexavalent chromium measurement in polymers and electronics.
  • IEC publisher page for quantitative hexavalent chromium measurement in polymers and electronics by the colorimetric method.
"measure hexavalent chromium"
webstore.iec.ch2 citations
Referenced sections
  • IEC publisher page for phthalate determination in polymers by GC-MS and pyrolyzer or thermal-desorption GC-MS.
  • IEC publisher page for phthalate determination in polymers by GC-MS and pyrolyzer or thermal-desorption GC-MS methods.
"Phthalates in polymers"
More quoted passages
"Phthalates in polymers by gas chromatography-mass spectrometry"
webstore.iec.ch2 citations
Referenced sections
  • IEC publisher page for the international technical-documentation standard used for restricted-substance assessment.
  • IEC publisher page for the international technical-documentation standard on which EN IEC 63000:2018 is based.
"specifies the technical documentation"
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