RoHS Testing Lab for Product Compliance

Determine whether your materials and products meet applicable RoHS substance restrictions with a testing strategy adapted to your product, materials and available supplier documentation.

Enviropass provides complete RoHS testing through our Montreal, Canada laboratory operations, including heavy metals and hexavalent chromium [Cr(VI)] analysis.

For complex products, laboratory testing can also be combined with supplier documentation and a risk-based technical assessment to avoid unnecessary testing while building stronger compliance evidence.

Learn about RoHS compliance.

Do You Need RoHS Testing?

RoHS compliance does not necessarily mean testing every component or material in a finished product.

There are two complementary ways to establish RoHS compliance evidence:

Analytical testing evaluates samples or homogeneous materials for restricted substances using appropriate laboratory methods from the IEC 62321 series.
Documentary assessment evaluates supplier declarations, test reports, material information and other technical documentation. IEC 63000 provides a framework for compiling technical documentation used to demonstrate compliance with substance restrictions. IEC describes the standard specifically as covering the technical documentation manufacturers compile to declare compliance.

For complex electrical and electronic equipment, the most efficient strategy is often a combination of documentary review and targeted laboratory testing.

Testing is particularly useful when:

supplier documentation is missing, outdated or insufficient;
a material presents a higher risk of containing a restricted substance;
supplier information is inconsistent;
additional evidence is needed to support a compliance conclusion; or
a specific material or substance needs to be verified.

Testing is most effective when it supports a wider RoHS and REACH product compliance assessment based on the BOM, supplier evidence and identified gaps.

Not sure what needs to be tested?

Enviropass can review your product, BOM and available documentation before defining the laboratory scope.

What Does EU RoHS Testing Cover?

EU RoHS currently restricts ten substances at the homogeneous-material level. Directive (EU) 2015/863 added DEHP, BBP, DBP and DIBP to Annex II of Directive 2011/65/EU.

Restricted substance	Maximum concentration*
Lead (Pb)	0.1%
Mercury (Hg)	0.1%
Cadmium (Cd)	0.01%
Hexavalent chromium [Cr(VI)]	0.1%
Polybrominated biphenyls (PBB)	0.1%
Polybrominated diphenyl ethers (PBDE)	0.1%
DEHP	0.1%
BBP	0.1%
DBP	0.1%
DIBP	0.1%

*Maximum concentration values by weight in homogeneous materials, subject to applicable exemptions.

A finished product may therefore contain many different homogeneous materials requiring separate consideration. Testing should be planned according to the material type, potential substance risk and available compliance evidence.

Where a restricted substance is intentionally or technically present, an applicable RoHS exemption may also need to be assessed.

RoHS Testing Methods

The appropriate analytical method depends on the material and substance being investigated.

XRF Screening

X-ray fluorescence spectroscopy (XRF) provides rapid, generally non-destructive screening of homogeneous materials.

For RoHS applications, XRF can screen for elements including:

lead;
mercury;
cadmium;
total chromium; and
total bromine.

The current IEC 62321-3-1:2026 standard covers XRF screening and replaced the 2013 edition in May 2026.

An important limitation is that XRF measures total chromium, not hexavalent chromium specifically. Similarly, total bromine screening does not by itself identify whether PBB or PBDE is present.

Depending on the screening result and compliance objective, additional substance-specific testing may therefore be required.

Hexavalent Chromium [Cr(VI)] Analysis

Where Cr(VI) is a concern, substance-specific analysis is required rather than relying only on total chromium measured by XRF.

For corrosion-protected coatings on metals, IEC 62321-7-1 describes a colorimetric method for determining the presence of Cr(VI).

Enviropass performs hexavalent chromium analysis as part of our Montreal RoHS laboratory capabilities.

PBB and PBDE Testing

Bromine detected through screening does not automatically mean that a material contains PBB or PBDE.

Where additional analysis is needed, substance-specific laboratory methods can be used. IEC 62321-6 covers the determination of PBB and PBDE in polymers, including GC-MS.

RoHS Phthalate Testing

The four RoHS-restricted phthalates are:

DEHP, BBP, DBP and DIBP.

IEC 62321-8 describes GC-MS-based methods for determining these and other specified phthalates in polymers used in electrotechnical products.

Our RoHS Testing Process

1. Define the compliance objective

We identify the applicable market, product and RoHS requirements.

2. Review the product and available evidence

Where appropriate, we review the BOM, materials, supplier declarations, and existing test reports.

3. Develop the sampling plan

We identify which homogeneous materials and restricted substances require testing.

4. Perform the appropriate laboratory analyses

The analytical techniques are selected according to the material, substance and compliance objective.

5. Review the results

Results are evaluated against the applicable RoHS requirements, concentration limits and relevant exemptions.

6. Determine the next steps

We provide a compliance conclusion or identify additional documentation, testing, or corrective actions required.

RoHS Testing vs. Documentary Assessment

Laboratory testing is an important source of RoHS evidence, but testing alone is not always the most efficient way to assess a complex electrical or electronic product.

For products containing many components and homogeneous materials, manufacturers can combine:

Supplier evidence
Declarations of conformity, material declarations, specifications and existing test reports.

Risk assessment
Evaluation of materials, components and supplier evidence to determine where compliance risk remains.

Targeted analytical testing
Laboratory testing of materials for which existing evidence is insufficient or where the risk warrants confirmation.

Technical documentation
Compilation of the resulting evidence according to an approach consistent with IEC 63000.

This combination can reduce unnecessary testing while ensuring that higher-risk or insufficiently documented materials receive appropriate attention.

Need a complete product assessment rather than laboratory testing alone?

Why Work With Enviropass for RoHS Testing?

Montreal RoHS Laboratory Operations

Complete RoHS testing is available through our Montreal, Canada laboratory operations, including heavy metals and hexavalent chromium analysis.

Risk-Based Testing Strategy

We help identify what actually needs to be tested based on your materials, product design, supplier documentation and regulatory objective.

Testing Connected to Compliance

Rather than providing laboratory data in isolation, we can evaluate the results in the context of your product compliance assessment and identify the evidence or corrective actions still required.

RoHS Testing FAQ

Is RoHS testing mandatory?

RoHS compliance is mandatory for products within the applicable scope, but laboratory testing of every material is not automatically required.
Manufacturers must have sufficient evidence to demonstrate compliance. Depending on the product and available supplier documentation, that evidence may include declarations, technical documentation, material information and targeted analytical testing.

Which substances are tested under RoHS?

EU RoHS currently restricts ten substances: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP. Most have a maximum concentration value of 0.1% by weight in homogeneous material, while cadmium has a limit of 0.01%.

Can XRF prove that a product is RoHS compliant?

Not by itself.
XRF is an extremely useful screening technique for elements such as lead, mercury, cadmium, total chromium and total bromine. However, it does not distinguish hexavalent chromium from other forms of chromium and does not directly identify PBB, PBDE or the four restricted phthalates.
The results must therefore be interpreted according to the material, substance and applicable analytical method.

Do I need to test every component in my product?

Not necessarily.
For complex products, a risk-based approach can combine supplier documentation with targeted analytical testing. IEC 63000 addresses technical documentation for demonstrating compliance with substance restrictions.

Is a RoHS test report enough to demonstrate compliance for the entire product?

A laboratory report establishes the results for the samples and materials included in its scope.
Whole-product compliance may additionally require consideration of other homogeneous materials, supplier evidence, applicable exemptions, and technical documentation.

How long does RoHS testing take?

The timeline depends on the number and type of samples, required analytical methods and whether additional sample preparation or confirmatory testing is necessary.
We define the testing scope and expected timeline after reviewing your product and compliance objective.

Technical Review

Written and technically reviewed by: Aurélien “Aury” Hathout, M.Env., VEA®, CEA

Last technical review: September 2026

This page was reviewed for technical accuracy against the EU RoHS Directive, Directive (EU) 2015/863, the IEC 62321 series, and IEC 63000.

For information on how Enviropass reviews technical content and selects regulatory sources, see our Editorial Policy.

Key Regulatory and Technical References

EU RoHS Directive 2011/65/EU — legal framework for the restriction of hazardous substances in EEE.

Commission Delegated Directive (EU) 2015/863 — Annex II restricted substances, including the four phthalates.

IEC 62321-3-1:2026 — XRF screening.

IEC 62321-7-1:2015 — Cr(VI) in corrosion-protected coatings on metals.

IEC 62321-6:2015 — PBB and PBDE in polymers.

IEC 62321-8:2017 — phthalates in polymers.

IEC 63000:2016+A1:2022 — technical documentation for assessment of EEE with respect to restricted substances.