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Ensuring Compliance with RoHS, REACH, and Prop. 65 through Electronic Product Testing

Electronic product testing helps manufacturers identify and quantify substances relevant to RoHS, REACH and California Proposition 65. Laboratory results support compliance assessments, but they do not automatically demonstrate that an entire product meets every applicable requirement. A suitable assessment combines regulatory scope, supplier documentation, material information and targeted testing where needed.

Is Chemical Testing Mandatory for Electronic Products?

There is no universal requirement under RoHS, REACH or California Proposition 65 to laboratory-test every electronic product or component. The evidence needed depends on the applicable obligations, product materials, available supplier information and specific compliance risks.

Testing is particularly useful when:

  • Supplier declarations or material information are missing or unreliable.

  • Existing reports do not cover the relevant part, material or substance.

  • A material presents a risk that cannot be resolved through documentation.

  • A customer specification or applicable requirement calls for a particular test.

For complex electronics, reviewing the bill of materials and supplier evidence helps identify where laboratory analysis will provide useful additional information.

A test report supports conclusions about the samples, substances and methods within its scope. It does not automatically establish compliance for untested materials or other regulatory obligations.

Laboratory Enviropass

Electronic Product Testing against RoHS

RoHS, or the Restriction of Hazardous Substances Directive, is a European Union directive that limits the use of certain hazardous substances in electronic products. These substances include:

RoHS
  1. Lead
  2. Mercury
  3. Cadmium
  4. Hexavalent chromium
  5. Polybrominated biphenyls (PBBs),
  6. Polybrominated diphenyl ethers (PBDEs).
  7. Bis(2-Ethylhexyl) phthalate (DEHP)
  8. Benzyl butyl phthalate (BBP)
  9. Dibutyl phthalate (DBP)
  10. Diisobutyl phthalate (DIBP)

RoHS concentration limits apply to each homogeneous material, rather than to the overall weight of a finished product. The maximum permitted concentration is generally 0.1% by weight for each restricted substance, except cadmium, which has a maximum of 0.01%. Applicable exemptions must be assessed against their specific conditions.

Electronic product testing

The directive applies to a wide range of products, including:

Manufacturers of electrical and electronic equipment within the scope of EU RoHS must demonstrate conformity and prepare the required technical documentation. Supporting evidence may include supplier declarations, material information, existing test reports and additional laboratory testing where needed. Testing every component is not automatically required.

Other markets have their own substance restrictions and documentation requirements, which must be assessed separately.

Learn how Enviropass plans RoHS laboratory testing around your materials and available compliance evidence.

Electronic Product Testing for REACH and SCIP

REACH SVHC

REACH regulates chemicals and can impose obligations on substances present in electronic products. It does not generally require manufacturers to register every chemical contained in a finished electronic device.

For electronics supplied as articles, the assessment should distinguish several obligations:

  • REACH Article 33: Suppliers must communicate sufficient safe-use information, including at least the substance name, when a Candidate List SVHC exceeds 0.1% by weight in an article. Information must be provided to professional recipients; consumers can request it and must receive a response within 45 days.

  • REACH Annex XVII: Restrictions must be checked against the substance, material, product and use covered by each entry. The Candidate List threshold of 0.1% is not a universal Annex XVII limit.

  • REACH Article 7: Substance notification or registration may apply under specific conditions. For example, registration can be required for substances intentionally released from articles when the applicable tonnage and other conditions are met.

For an assembled product, the SVHC assessment must consider its constituent articles rather than simply averaging substance content across the entire device.

How Does SCIP Differ from REACH Registration?

SCIP is ECHA’s database for information on Candidate List SVHCs in articles, established under the EU Waste Framework Directive.

Suppliers subject to the SCIP obligation must submit information about articles placed on the EU market containing a Candidate List SVHC above 0.1% by weight. SCIP reporting does not register a substance under REACH, replace Article 33 communication or establish compliance with Annex XVII restrictions.

See ECHA’s SCIP guidance for the applicable reporting requirements.

When Does REACH Testing Help?

Testing can help resolve gaps in supplier information or quantify selected substances. The analyte list, sampling plan and calculation basis must match the relevant article or restriction.

A test panel alone cannot establish compliance with every REACH obligation. Documentation review, product structure and supply-chain responsibilities also matter.

Explore our RoHS and REACH product assessment service.

Electronic Product Testing for California Proposition 65

California Proposition 65

California Proposition 65 requires covered businesses to provide clear and reasonable warnings before exposing individuals to listed chemicals, unless an exemption applies.

The presence of a listed chemical in an electronic product does not, by itself, establish that a warning is required. The assessment must consider potential exposure during reasonably foreseeable use and the applicable warning exemptions or safe harbor levels.

Laboratory testing can identify or quantify selected chemicals and support an exposure assessment. However, a concentration result alone does not necessarily establish the amount to which a person may be exposed.

Depending on the product, relevant evidence may include supplier composition data, material testing, migration or release testing, and an evaluation of how users interact with the product.

For official guidance, consult OEHHA’s Proposition 65 business resources.

Analytical Methods Used in Electronic Product Testing

RoHS testing lab

The appropriate analytical method depends on the material, substance of concern and compliance question. No single instrument can determine whether an electronic product meets every RoHS, REACH or Proposition 65 requirement.

A testing plan should identify the samples, target substances, preparation procedures and reporting limits needed to support the assessment.

X-Ray Fluorescence (XRF) Screening

XRF measures characteristic X-rays emitted by elements in a sample. It provides rapid elemental screening, often with limited sample preparation.

For RoHS assessment, relevant screening results include lead, cadmium, mercury, total chromium and total bromine. IEC 62321-3-1 addresses XRF screening of materials in electrotechnical products.

XRF has important limitations:

  • Total chromium does not distinguish hexavalent chromium, Cr(VI), from other chromium forms.

  • Total bromine does not identify specific brominated compounds such as PBBs or PBDEs.

  • XRF does not directly identify the four RoHS-restricted phthalates.

  • Coatings, sample thickness, geometry and mixed materials can affect interpretation.

Screening results help determine whether additional testing is needed. Measuring an assembled component without considering its different materials can produce misleading compliance conclusions.

xrf-spectrometry-method

UV-Vis Spectrophotometry and Hexavalent Chromium Testing

UV-Vis spectrophotometry measures the absorption of ultraviolet or visible light. With suitable sample preparation and a selective colour-forming reaction, it can support the determination of specific substances.

For RoHS, colorimetric methods are used to assess hexavalent chromium:

  • IEC 62321-7-1 addresses the presence of Cr(VI) in corrosion-protection coatings on metals.

  • IEC 62321-7-2 addresses Cr(VI) in polymers and electronics.

These methods have different sample preparation and reporting approaches. A coating-presence result should not be treated as equivalent to a bulk-material concentration in ppm.

Electronic product testing

Chromatography and GC-MS

Chromatography separates substances in a sample. The appropriate technique and detector depend on the target compounds and material.

Gas chromatography–mass spectrometry (GC-MS) combines separation by gas chromatography with mass spectrometric detection to identify and quantify selected organic compounds.

Applications relevant to electronics include:

  • PBBs and PBDEs in polymers: addressed by IEC 62321-6.

  • Phthalates in polymers: addressed by IEC 62321-8, which includes GC-MS and a pyrolysis/thermal-desorption GC-MS approach.

GC-MS can also support investigations of other organic substances when a suitable method is available. It is not a universal test for every REACH substance or persistent organic pollutant.

The report should identify the compounds assessed and the applicable detection or quantification limits.

Wet Chemistry and Sample Preparation

Wet chemistry includes procedures such as extraction, digestion and chemical reactions used to prepare samples or measure selected substances.

For example:

  • Acid digestion may prepare a material for elemental analysis.

  • Extraction may transfer selected organic compounds into a solvent for chromatographic analysis.

  • A colour-forming reaction may enable measurement of Cr(VI) by spectrophotometry.

The preparation procedure must suit the material and target substance. Incomplete extraction, contamination or changes to the substance during preparation can affect the result.

Atomic Absorption Spectroscopy (AAS)

AAS measures the absorption of element-specific light by free atoms. It can quantify selected elements, usually after suitable sample preparation.

Depending on the element and method, atomization may use a flame, graphite furnace or a specialized technique such as cold vapour for mercury.

AAS measures elemental content; a conventional total-chromium measurement does not distinguish Cr(VI) from other chromium forms. Substance-specific methods are needed when the chemical form determines the compliance requirement.

ICP-OES and ICP-MS

Inductively coupled plasma techniques use a high-temperature plasma to analyse elements in prepared samples.

ICP-OES — Optical Emission Spectrometry

ICP-OES measures characteristic light emitted by excited atoms and ions. It supports the determination of multiple elements, including metals relevant to product compliance.

ICP-MS — Mass Spectrometry

ICP-MS measures ions according to their mass-to-charge ratios. It often provides lower detection limits than ICP-OES, although performance depends on the element, sample matrix, preparation and interferences.

IEC 62321-5 includes AAS, ICP-OES and ICP-MS methods for specified determinations of cadmium, lead and chromium in electrotechnical materials.

Neither ICP technique, when used for conventional total-element analysis, automatically identifies the chemical compound or oxidation state present.

Interpreting Electronic Product Test Results

A useful report identifies the tested sample or material, analytical method, target substances, results, units and relevant reporting limits.

When assessing the findings:

  • Confirm that the sample represents the material used in the product.

  • Apply the correct assessment basis, such as the homogeneous material for RoHS.

  • Distinguish total-element results from substance-specific measurements.

  • Check whether reporting limits are suitable for the assessment.

  • Consider measurement uncertainty and the applicable decision rule when drawing a conformity conclusion.

“Not detected” means below the method’s detection limit; it does not establish absolute absence.

Laboratory results should be assessed alongside supplier documentation, product structure and applicable regulatory conditions.

Electronic Product Testing instruments

Learn more about our RoHS testing services or request a product compliance assessment.

Technical Review

Reviewed and updated by Aurélien “Aury” Hathout, M.Env., VEA®, CEA, President of Enviropass Expertise Inc.

Last technical review: October 10, 2026

For information about our content review process and selection of regulatory sources, see the Enviropass Editorial Policy.

Technical Review