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 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 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.
A RoHS Certificate of Conformity (or RoHS CoC) is a manufacturer’s statement that indicates the RoHS status. Overall, a CoC can apply to all the production, some series, or only one part number. CoC can be issued by an independent third party after verifying that the product meets regulatory requirements.
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. DoC can be self-issued, , stating that the product complies with relevant regulations.
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:
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.
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.
First-of-all, the objective of RoHS regulations is to reduce the concentrations of certain heavy metals or hazardous additives in electronics.
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.
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.
Since 2013, the CE marking constitutes the only RoHS product label in the EU. Besides, the CE marking covers other requirements than RoHS.
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.
A RoHS Declaration of Conformity is a formal document stating that electrical or electronic equipment complies with the EU RoHS Directive. It confirms that the product meets the applicable restrictions for hazardous substances such as lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP.
Yes, for products within the scope of EU RoHS. Manufacturers must prepare technical documentation and issue an EU Declaration of Conformity before placing covered electrical and electronic equipment on the EU market. The declaration supports CE marking and demonstrates that the manufacturer accepts responsibility for compliance.
A RoHS Declaration of Conformity should typically include the manufacturer’s name and address, product identification, the applicable legislation, relevant standards, a statement of conformity, the authorized signatory, the date of issue, and the signature. It should clearly identify the product covered by the declaration.
Yes. EU RoHS is a CE marking directive for covered electrical and electronic equipment. This means RoHS compliance must be addressed before affixing the CE mark to products within the scope of the directive.
No. Supplier declarations can support compliance, but they do not replace the manufacturer’s responsibility to issue the final Declaration of Conformity for the product placed on the EU market. Manufacturers should review supplier evidence and keep appropriate technical documentation.
The declaration should be signed by an authorized person who can represent the manufacturer or responsible economic operator. The signer should have authority to declare that the product complies with the applicable RoHS requirements.
For EU RoHS, technical documentation and the EU Declaration of Conformity should generally be kept for 10 years after the product is placed on the EU market. Companies should also ensure that declarations remain updated when product designs, suppliers, materials, or regulations change.
Common mistakes include missing product identification, outdated directive references, incorrect standards, unsigned declarations, unclear manufacturer information, expired exemptions, unsupported compliance claims, or declarations that do not match the actual product configuration.
Yes, when relevant. If compliance depends on a RoHS exemption, the exemption should be clearly identified and supported by technical documentation. Companies should also track exemption expiry dates and renewal status.
Yes. Enviropass can help review product scope, assess RoHS substance risks, collect supplier documentation, verify exemptions, coordinate testing when needed, prepare technical documentation, and support the preparation of a RoHS Declaration of Conformity.
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