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You have to verify whether your products are RoHS compliant. It can be one product intended for a specific EU market, multiple models, or even your entire production. Your designs can have a dozen or thousands of different components, depending on their complexity. Therefore, you are considering RoHS testing of electrical or electronic equipment against the RoHS requirements. If this applies to you, read below!

Two Possible RoHS Testing Approaches

RoHS testing approaches

How do you test your products and verify their compliance against the RoHS substances? In other words, what kind of information is necessary and sufficient to perform valuable RoHS conformity assessments?

You essentially have two options: either you do the test yourself or benefit from tests a stakeholder in your supply chain has already conducted. Then, you will use the gathered information to make your technical file. In other words, the sources of information are:

  1. RoHS analytical tests, per standard IEC 62321 or
  2. Supply chain audit, with a documentary review, following standard IEC 63000.

#1: Analytical RoHS Testing

With the analytical testing approach, you will do physical testing on samples. We can find various types of analytical testing on the market, depending on the chemicals to be analyzed. Here are some of the main ones. 

XRF Spectrometry Method

Probably the most popular analytical testing method is the XRF one. XRF means X-ray fluorescence

With this method, it is possible to identify a material composition by bombarding it with high-energy X-rays. Then, the emission of “secondary” (or fluorescent) X-rays gives the nature of the excited atoms. The XRF method detects the presence and concentration of heavy metals like lead in a homogeneous material. XRF is one of the least expensive analytical testing methods.

Chromatography for RoHS Testing

Chromatography consists of chemically separating the elements of a dissolved mixture. As a result, chromatography allows us to identify and quantify these elements.

Gaz chromatography detects PBB, PBDEs, or phthalates and determines their concentration in a given material.


Sampling Plan

The analytical testing approach works well when verifying compliance with specific materials. While it is usually not the primary approach to test complex products, lab testing helps you confirm compliance. Get a sampling plan to prioritize the tests you must have:

  • Homogeneous materials. Remember: RoHS applies to materials of uniform composition. Therefore, we want to determine in advance what you must test! 
  • Samples for testing. You don’t necessarily have to send an entire unit. However, the parts or materials must be in sufficient quantities for testing. The necessary weight depends on the material nature (for example, metal VS. polymers) and the targeted restricted chemicals (heavy metals, brominated compounds, or phthalates). 
  • Ensure compliance over time. You will receive the RoHS information of one specific sample at a time. Should you then do multiple tests to ensure your product remains RoHS compliant? For example, a design or a sourcing revision will trigger the need to update your analytical testing.
RoHS destructive testing

To confirm your RoHS sample plan, ask an Enviropass expert!

#2: Supply Chain Audit and RoHS Documentary Review

Since it is not realistic to do comprehensive analytical testing on your products, another option is available: the Documentary approach. Here, you will perform a risk analysis based on your product bill of materials and use the information your suppliers have already collected from their suppliers to confirm compliance with RoHS.

Manufacturers Certificates of Compliance

Enviropass recommends gathering as much relevant RoHS information as possible from your supply chain, building a robust technical file, and demonstrating due diligence. As a rule of thumb:

  • Manufacturing suppliers know their parts better than you do;
  • Their products are not as complex as yours, and
  • They deal directly with their suppliers of components or materials.
RoHS experts of components

Therefore, they are more likely to commit to the RoHS compliance of their parts. 

When available, their certificates of compliance (CoC) are significant pieces of information as long as :

  • They are up-to-date in terms of listed RoHS substances and exemptions. You should be able to find out whether RoHS exemptions apply with valid references;
  • They cover the parts under investigation;
  • They are consistent with the anticipated likelihood of RoHS substances in a given component.
RoHS Certificate of Compliance

A CoC can be of different formats. Use the Enviropass EPEC form to gather the needed environmental information from your supply chain. 

Other documents, such as specifications and harmonized safety data sheets, may also enable you to determine the RoHS status of certain materials. 

Likewise, you can use testing reports as proof of compliance. However, test reports of samples don’t guarantee that all supplied parts remain compliant over time. Therefore, the supplier of parts should accompany its test report by a CoC.

RoHS statement signature

Should I Follow the RoHS Documentary Approach?

The quick answer is yes for complex products like electronic devices with more than ten homogeneous materials. 

IEC 63000

To help you build sufficient technical documentation, the International Electrotechnical Commission (IEC) has issued Standard 63000 for technical documentation for electrical and electronic products assessment concerning the restriction of hazardous substances. Here is what the IEC 63000 Standard states in its introduction:

For those restrictions that apply at the ‘homogeneous material’ level, it is impractical for manufacturers of complex products to undertake their (…) testing of all materials contained in the final assembled product. 

Instead, manufacturers work with their suppliers to manage compliance and compile technical documentation as evidence of compliance.

Therefore, IEC 63000 promotes technical documentation with a documentary review for complex products. Both industry and most enforcement authorities recognize this approach.


Along with IEC, CENELEC (European Committee for Electrotechnical Standardization) recommends the documentary approach towards RoHS compliance. Indeed:

BOM Enviropass

It is a comprehensive method. You will assess the documents of every product component and homogeneous material.

BOM Enviropass

It is reliable because it is comprehensive and relies on suppliers’ statements. 

BOM Enviropass

Based on quality control of the collected information, you can rely on the statements you receive.

BOM Enviropass

Importantly, it is cost-effective. The tests themselves are much less expensive than chemical analyses. 

BOM Enviropass

It is not destructive. Reuse the tests that your supply chain has already completed. Implement a quality control system to verify the statements and reports you receive from your supply chain are up-to-date and consistent with the RoHS requirements. 

BOM Enviropass

It is a sustainable method because it avoids product transportation and destruction.

Finally, to update your technical file, you only need to gather the missing information for the additional parts according to the latest applicable regulatory changes.

The RoHS documentary review is an efficient approach that you can easily update for new product versions. 

What are the benefits of RoHS Analytical Testing?

RoHS analytical testing or documentary verification

Analytical testing may be necessary for medium to high-risk homogeneous materials without sufficient RoHS compliance guarantee from the suppliers. Here is why:

For a part without sufficient RoHS information that is risky according to your IEC 63000 type assessment, you can try to find a compliant replacement, like an alternative part. However, in some cases, it is impossible to replace that part because there is no alternative. Then, you will initiate an analytic testing plan on the risky homogeneous materials.

If the suspected restricted substance is present in the risky homogeneous material, then corrective actions are necessary to make the product compliant. For instance, it may be changing the design to bypass this part.

How do I Assure RoHS Compliance through RoHS Testing?

Here are some takeaways: 

  • Have a compliance plan that you will detail in an internal RoHS procedure to show how you perform due diligence. Get organized and follow a PDCA (Plan-Do-Check-Act) strategy for RoHS testing improvement. Here, the IECQ QC 080000 standard may help you. 
  • Have a risk analysis approach per the well-recognized IEC 63000 standard.
RoHS Compliance documentary method
  • Checking that suppliers are RoHS compliant is not sufficient. Some other details must be collected, such as the claimed exemptions. The documentary method and quality control enable a demonstration of due diligence;
  • You ideally want a commitment from your suppliers that your parts are and will remain EU RoHS compliant, either with or without exemption. These statements are certificates of compliance (CoC);
  • Make sure the CoCs are up-to-date and enable you to confirm RoHS compliance. For example, does the CoC cover the four RoHS phthalates?
  • Verify the exemption status. Are the exemptions still valid? If not, then the part is no longer RoHS compliant. If no exemptions are expressly stipulated, can you reasonably assume that the part does not or can’t benefit from any exemption?
  • Use our to-date EPEC form to scan your suppliers and gather their statements;
  • Execute analytical testing on specific homogeneous materials when you can only modify your product design.
Approved RoHS compliant product

What is the RoHS Meaning and RoHS Testing

First, let’s briefly recap what RoHS is. RoHS stands for:


Of certain 



RoHS applies to electrical and electronic equipment (EEE). Tens of countries, especially in Europe and in Asia, even some US states, have voted for RoHS regulations. EU RoHS has pioneered in this sector and remains a reference.

RoHS Testing
RoHS exemption

RoHS usually targets these six substances:

  • Four heavy metals: chromium hexavalent, lead, mercury, cadmium, and their compounds
  • Two brominated families: Polybrominated biphenyls (PBBs) and Polybrominated diphenyl ethers (PBDEs)

Some countries have added four phthalates to the RoHS list: 

  • Butyl benzyl phthalate (BBP)
  • Di-n-butyl phthalate (DBP)
  • Di(2-Ethylhexyl) phthalate (DEHP)
  • Diisobutyl phthalate (DIBP)

Different compliance rules apply, depending on the RoHS regulation. For example, the scope varies a lot from one market to another. But what remains the same is that the restrictions apply at the homogeneous material level and are reasonably low, either 0.1% or 0.01%. Additionally, various applications and materials benefit from RoHS exemptions. For example, lead in some copper alloys can exceed the general concentration limit of 0.1% under certain conditions. Since these exemptions are regularly revised, you should monitor the RoHS exemptions that apply to your products and ensure they remain compliant.

Then, you should be able to prepare your product declaration of compliance.

Ask Enviropass for a free online consultation to see a RoHS technical file.

*Note: This article shows the current understanding of Enviropass Expertise Inc. It is developed solely for information purposes and can not replace official legislation.