RoHS compliance for electrical imports from China
Establish the product’s scope, build material evidence for the exact production specification, verify any claimed exemption and secure the declaration and technical file before release. Keep responsibility and document access clear. Cambridge China Bridge can coordinate factory evidence through its staff in China.
Record why the product is in scope
Electrical and electronic equipment, including cables and spare parts, is in scope unless specifically excluded. This guide focuses on Great Britain. Northern Ireland needs a separate assessment because some provisions differ. Record the intended market, product functions and reasons for your scope decision.
Ask the factory to identify the finished model, supplied accessories and intended use. If it claims an exclusion, request the exact provision and a written explanation of how the product fits it. Keep the wider product checks alongside this assessment using our guide to importing electrical goods.
Build evidence around materials and components
Request a controlled BOM identifying component suppliers and material specifications. Organise the evidence by homogeneous material, such as solder, cable insulation, plating and moulded plastic. Ask for substance declarations and relevant laboratory reports linked to those materials, rather than accepting a statement that the assembled product is compliant.
Ask the laboratory to compare the evidence against the complete current restricted-substance list and applicable limits. Check whether supplied reports cover the substance groups you need, the actual materials and the production configuration. Create an evidence register showing each material, its supporting document and any unresolved gap. For product selection, see our guide to planning your compliance budget.
Resolve gaps before accepting a report
Check report authenticity with the issuing laboratory. Match sample descriptions, photographs, component references and material grades to your order. A report for an enclosure does not answer questions about solder or cable insulation. Ask the laboratory to explain inconclusive results and recommend targeted testing where the existing evidence leaves a gap.
Agree which samples will be submitted and how they represent production. Keep photographs and sample references with the results. Separate substance checks from appearance and assembly checks; our guide to laboratory testing or factory inspection helps you brief the right work.
Check each claimed exemption
Exemptions can permit restricted substances above their prescribed limits for specific technical applications. Ask the supplier for the exact exemption reference, affected component, substance, application and claimed validity. Check the current official exemption information and determination summaries, rather than accepting an old report’s exemption note.
Confirm with the relevant authority which exemption system applies in Great Britain. Have the claimed exemption checked for your intended market and application. Keep the wording, supporting technical explanation and review date in the product file. Ask the supplier to propose an alternative material or component if the claimed exemption cannot be substantiated.
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Secure documents and control production changes
As importer, ask the relevant authority to confirm your duties for checking the manufacturer's conformity work, declaration, marking and technical documentation, and for keeping records available. Confirm whether selling under your own name or trade mark brings manufacturer responsibilities. Our CE and UKCA guide discusses those roles without confusing a laboratory report with the declaration.
Keep a local evidence index and agree reliable access to the underlying file. Link it to the approved BOM, reports, exemption assessment and signed declaration. Require proposed substitutions to be reviewed before production through the process in approving material and component substitutions. Cambridge China Bridge’s staff in China can coordinate evidence collection and compare production components with the agreed specification.
Frequently asked questions
Is a supplier’s RoHS certificate enough?
Check what it actually covers. Request material evidence for the production specification, verify reports with the laboratory and secure the declaration and technical file.
Does every component need a new RoHS test?
Review existing material declarations and reports first. Ask a laboratory to identify evidence gaps and propose targeted testing rather than ordering an unspecified whole-product test.
How do I check a RoHS exemption?
Obtain the exact reference and affected application. Check current official exemption information for the intended market, then retain the wording and supporting explanation.
Who is responsible for RoHS documentation?
Confirm with the relevant authority who must prepare the conformity documentation, what the importer must check and which records must remain available. Also confirm whether selling under your own name or trade mark brings manufacturer responsibilities.