RoHS certification for the EU, the EAEU and Saudi Arabia

RoHS certification is a declaration you sign, not a certificate anyone issues. Directive 2011/65/EU restricts ten substances in electrical and electronic equipment, each capped at 0.1 % by weight in any homogeneous material and cadmium at 0.01 %. You compile technical documentation to EN IEC 63000, sign an EU declaration of conformity and apply the CE marking. A "RoHS certificate" is a laboratory test report or a body's voluntary attestation, and market surveillance asks for the file behind it. The Eurasian Economic Union and Saudi Arabia run their own RoHS regimes with six substances each.

Is there such a thing as a RoHS certificate?

No authority, laboratory or Notified Body issues a RoHS certificate, because the RoHS directive puts the whole assessment on the manufacturer. Article 7 of Directive 2011/65/EU says you draw up the technical documentation and run internal production control under module A of Annex II to Decision No 768/2008/EC, then draw up an EU declaration of conformity and affix the CE marking to the finished product. The declaration follows the model in Annex VI, and Article 13 requires it in the language of every member state where the product is sold.

What a supplier hands you as a "RoHS certificate" is one of two things. Either a test report from a laboratory that measured the ten substances in the samples it received, to the IEC 62321 series, or a voluntary attestation from a certification body that reviewed the file. Both are evidence inside your documentation and neither replaces the RoHS declaration of conformity you sign. This is the same structure as the rest of CE marking: the directive is self-assessed for every product category, with no Notified Body route at all.

The mistake we see most is the component certificate used as product evidence. A relay supplier's report proves the relay. It says nothing about the solder your assembler used, the plating on the enclosure screws or the plasticiser in the cable jacket, and those are where lead, cadmium and the four phthalates turn up. Under Article 9 an importer must check that the manufacturer has carried out the conformity assessment and drawn up the technical documentation before placing the product on the market, so a file made of supplier certificates alone fails at the importer's desk, before any authority sees it.

Which products and substances does the RoHS directive cover?

Annex I lists eleven categories: large household appliances, small household appliances, IT and telecommunications equipment, consumer equipment, lighting equipment, electrical and electronic tools, toys, leisure and sports equipment, medical devices, monitoring and control instruments including industrial ones, automatic dispensers, and category 11, other EEE not covered by any of the above. Category 11 is what makes the scope open: since 22 July 2019 anything with an electrical or electronic function that is not excluded by Article 2(4) is in.

The exclusions in Article 2(4) are short and specific: military equipment, equipment designed to be sent into space, large-scale stationary industrial tools, large-scale fixed installations, means of transport other than non-type-approved electric two-wheelers, non-road mobile machinery for professional use only, active implantable medical devices, professionally installed photovoltaic panels, research and development equipment sold business to business, and pipe organs. An exporter of industrial equipment reads "large-scale stationary industrial tool" and stops there; a single machine that fits on a pallet and is installed by the customer is not one.

Annex II names the ten substances and their maximum concentration values by weight in homogeneous materials: lead, mercury, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers at 0.1 %, cadmium at 0.01 %, and the four phthalates DEHP, BBP, DBP and DIBP at 0.1 %, added by Delegated Directive (EU) 2015/863 and applied to medical devices and monitoring and control instruments from 22 July 2021. "Homogeneous material" is the unit of measurement, so the limit applies to the solder joint and to the paint layer separately, never to the product as a whole. Averaging across the product is the second most common way a RoHS file is wrong.

What goes in the RoHS technical file, and what do customs and market surveillance ask for?

The harmonised standard for the file is EN IEC 63000:2018, listed under Commission Implementing Decision (EU) 2020/659; its predecessor EN 50581:2012 was withdrawn from the Official Journal on 18 November 2021. Article 16 gives products assessed to a listed harmonised standard a presumption of conformity, so the file is the whole of RoHS compliance: a bill of materials down to homogeneous material, a risk assessment of which materials and suppliers could carry a restricted substance, the supplier declarations and analytical reports that close each risk, and the signed declaration. Article 7 requires the documentation and the declaration to be kept for ten years after the product is placed on the market.

RoHS testing follows from the risk assessment, not the other way round. A laboratory screens the high-risk materials by X-ray fluorescence to IEC 62321-3-1 and confirms anything close to a limit by wet chemistry under the later parts of the series. Testing every material of a finished product is affordable for a cable and out of the question for a machine, which is why a manufacturer with no bill of materials to homogeneous-material level has no RoHS file, whatever its supplier certificates say. We ask for the bill of materials before we ask for samples; the samples come last.

RoHS exemptions are in Annex III for all categories and Annex IV for medical devices and monitoring and control instruments, and every entry carries an expiry date. Under Article 5 an exemption for categories 1 to 7, 10 and 11 runs for up to five years and for categories 8 and 9 up to seven, a renewal application must be filed at least 18 months before expiry, and the exemption stays valid until the Commission decides. Entry 1(a), mercury in compact fluorescent lamps, expired on 24 February 2023; entry 2(b)(4)-I, mercury in induction lamps, expires on 24 February 2025. If your file relies on an exemption, the file has to name the entry and the date, because a declaration signed against an expired entry is a non-conforming product on the day of expiry.

RoHS is rarely checked at the EU border. The check comes from market surveillance, which asks the importer or the authorised representative for the declaration and the technical documentation, with a short deadline. The name and address the directive requires on the product are how the authority finds the person to ask. The CE marking carries a presumption of conformity under Article 16(1) only in the absence of evidence to the contrary, a missing file is that evidence, and the penalties the directive requires member states to set fall on the importer, which is why the electrical and electronic product importers we work with ask for the RoHS file at the same time as the LVD and EMC reports.

Does the EU file work for the EAEU and Saudi Arabia?

Largely, and that is the reason to build it properly once. In the Eurasian Economic Union the instrument is TR EAEU 037/2016 on the restriction of the use of hazardous substances in electrical and radio-electronic products, in force since 1 March 2020. It limits six substances, the original RoHS list without the phthalates, and it is confirmed by an EAC declaration of conformity registered by an applicant established in a member state, never by a certificate. Under scheme 1d the declaration rests on test reports you already hold, European reports included, translated into the Union's working language; once the translated reports are in, the declaration takes about a week. Scheme 3d means local testing inside the Union and starts from a week after the samples arrive. The declaration runs for one, three or five years or for a single batch, and it sits next to the EAC certificate under TR CU 004/2011 and TR CU 020/2011 that the same product usually carries. The schemes and lead times under TR CU 037 are set out in detail on the blog.

Saudi Arabia adopted a Technical Regulation for Restriction of Hazardous Substances in Electrical and Electronic Equipment through SASO, version 2 approved on 30 June 2022 and published in the Official Gazette on 29 July 2022. Its six substances and limits match the EAEU list, and its six product categories came into mandatory application in stages, small household appliances from 4 July 2022 and monitoring and control instruments last, on 26 December 2023. Article 5 requires a certificate of conformity from a SASO-approved notified body under Type 1a of ISO/IEC 17067, obtained through SABER and followed by a shipment certificate for every consignment, and the technical file must hold the supplier declaration in the form of the regulation's Annex 4, a risk assessment and the manuals. The regulation's own standard list starts with SASO IEC 63000, so the EU file is the right shape; what SASO adds is testing in an ISO/IEC 17025 laboratory of all components, or of at least three critical components chosen from an IEC 63000 risk analysis. How RoHS test reports reach SABER covers the laboratory side.

Batteries are outside the Saudi regulation and go under its battery regulation instead, and radio-transmitting products carry CST type approval on top, which is a national approval and outside this page. The practical order is EU file first, because it is the only one of the three that demands the bill of materials to homogeneous material, then the EAEU declaration on the translated reports, then the SABER certificate on the same reports plus whatever component tests the Saudi body asks for. Doing the three in any other order means paying for the laboratory twice.

The three RoHS regimes an exporter meets

The EU list of exemptions in Annexes III and IV changes by delegated directive several times a year, and every entry has an expiry date. A file that names an exemption has to be re-read against the consolidated text in force on the day the product is placed on the market.