RoHS Declaration of Conformity

RoHS regulations worldwide restrict the usage of certain hazardous substances in electrical and electronic products. Therefore, customs agents, customers, or other third parties may request a RoHS declaration of conformity. What are these documents?

RoHS Declaration VS Certificate of Conformity

RoHS statements of all sorts are available online. If you look at manufacturers’ websites, you will find many formats of RoHS letters. Most of the time, they are RoHS certificates of conformity.

What is a RoHS Certificate of Conformity?

A RoHS Certificate of Conformity (or RoHS CoC) is a manufacturer’s in-house statement that indicates the RoHS status. Overall, a CoC can apply to all the production, some series, or only one part number.

The Official RoHS Declaration of Conformity

Contrary to the CoC, de RoHS Declaration of Conformity (RoHS DoC) are documents required by law. In particular, custom agents may request the DoC of a device entering a jurisdiction. Importantly, DoCs must possess precise information.

What should an EU RoHS Declaration of Conformity Contain?

In the European Union (EU), annex VI of Directive 2011/65/EU shows what a RoHS declaration must contain. For example, the following details must appear on an EU RoHS DoC:

A unique reference of the product
The name and address of the manufacturer
This mention: This declaration of conformity is issued under the sole responsibility of the manufacturer (or installer)
The DoC object
A signature
A date

Two Additional Recommended Details on an EU RoHS DoC

Additionally, the RoHS declaration of conformity should refer to applicable harmonized standards. For example, standard IEC 63000 enables RoHS assessments of electronic products. If used, IEC 63000 should appear on the DoC.

Additional information is also welcome on the RoHS DoC. For example, it can be the list of applicable RoHS exemptions.

Summary of the RoHS Requirements

Drafting a RoHS declaration of conformity is not the only requirement under RoHS. Indeed, the RoHS DoC is only possible at the final stage of an assessment. Briefly, here are the main RoHS requirements.

Restriction of Hazardous Substances in Electrical and Electronic Equipment

First-of-all, the objective of RoHS regulations is to reduce the concentrations of certain heavy metals or hazardous additives in electronics.

Possible RoHS Exemptions

Yet, a list of exempted applications can contain restricted substances under certain conditions. Indeed, it may be impossible to prohibit RoHS substances for technical reasons. However, as technology evolves, these exemptions are subject to revisions. Therefore, manufacturers must ensure their products remain compliant under valid exemptions if any.

RoHS Technical File and Internal Procedures

Per the EU RoHS directive, manufacturers should draw up a procedure to verify and monitor RoHS compliance. Furthermore, they must maintain a RoHS technical file with evidence of compliance.

CE Marking

Since 2013, the CE marking constitutes the only RoHS product label in the EU. Besides, the CE marking covers other requirements than RoHS.

RoHS Declaration of Conformity

Finally, the RoHS Declaration of Conformity is one of these requirements. Manufacturers can draft a RoHS DoC on-demand once the product is deemed RoHS compliant.

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