RoHS Explained: Meaning, Substances and Compliance

What does RoHS mean for buyers sourcing from China?

RoHS controls specified hazardous substances in electrical and electronic equipment. Ask suppliers to identify the destination rules and evidence supporting any “RoHS compliant” claim.

Start with where the goods will be sold or supplied, their intended use and the exact model. The EU has a RoHS Directive. California has its own RoHS restrictions for covered electronic devices; assess those requirements separately.

Individuals buying for commercial resale, small businesses and larger importers should establish their role before ordering. Order size alone does not determine whether product rules apply.

Which substances does RoHS restrict, and at what concentrations?

The table gives the maximum concentration values listed in official UK RoHS guidance. For Great Britain, these appear in Schedule A1 to the RoHS Regulations 2012, as amended; the Northern Ireland provisions refer to Annex II to the EU Directive. Check destination-specific exclusions and exemptions.

Limits apply by weight to each homogeneous material: a material of uniform composition throughout, or a combination that cannot be separated into different materials mechanically. Do not average a restricted substance across the weight of the finished product.

DEHP, BBP, DBP and DIBP are the four added phthalates. A report covering only the original substances does not demonstrate coverage of these additions.

Who does RoHS apply to?

Check both product scope and supply-chain role. Manufacturers, importers and distributors have different obligations. Covered equipment can include household appliances, lighting, electronics and electrical tools, with exclusions and special provisions.

A factory’s location in China does not settle which destination rules apply. Give the supplier a written market specification rather than requesting an unspecified “export certificate”.

For product assessment and the purchasing workflow, continue to RoHS compliance for electrical equipment from China.

Do exemptions mean a product can contain restricted substances?

An applicable substance exemption permits concentrations above the usual limit for a specific technical application under stated conditions. It differs from excluding an entire product from scope.

Ask the supplier to identify the exact exemption, affected material, product category and validity conditions. Check the current official text and relevant determinations before relying on it.

Great Britain operates an exemption system independently of the EU. Northern Ireland follows the EU exemption system. Do not assume an exemption accepted in one market automatically applies elsewhere.

What documents should you ask a Chinese supplier for?

Request the applicable Declaration of Conformity, relevant test reports and supporting technical documentation. For purchasing review, also request a materials or component list and identification of any claimed exemptions.

Match the paperwork to the manufacturer, model, product photographs and materials being ordered. Check which substances and sampled materials the reports actually cover. Do not rely on visual similarity to establish that a report covers your goods.

Agree how material or component changes will be communicated. A test report is supporting evidence; it does not replace the manufacturer’s declaration or establish that subsequent production is unchanged.

How does RoHS connect to CE and UKCA marking?

RoHS has conformity assessment, declaration and marking requirements. A CE or UKCA symbol alone does not identify the materials assessed or provide the underlying technical evidence.

Great Britain accepts CE marking alongside UKCA for RoHS, subject to the applicable GB requirements, including exemptions. An EU exemption without a GB equivalent does not establish compliance for this route. Northern Ireland has different provisions. Other product legislation may also apply.

Use the electrical-equipment RoHS guide for the connection between documents, conformity assessment and CE or UKCA marking. For overlapping chemical requirements, read UK REACH versus RoHS.

UK worked example: enforcement and import costs

OPSS enforces RoHS in Great Britain and Northern Ireland. Responsible economic operators must take appropriate corrective action immediately when they have reason to believe their equipment is non-compliant, and notify OPSS immediately of discovered non-compliance. Corrective action can include withdrawal or recall.

Check import costs separately. Under HMRC’s transaction-value method, include transport, insurance, loading and handling costs to the UK border unless already included. Import VAT valuation also includes applicable import duties and relevant incidental expenses to the first UK destination, and transport-related expenses to a further UK destination known at importation, without double counting.

Paying import taxes or obtaining customs release does not establish RoHS compliance.

Before placing your order

Record the destination, intended use, model, materials, evidence reviewed and any exemption relied upon. Resolve missing or mismatched documents before approving production.

Agree who will collect and review the documents, the review scope and any specialist testing needed. Keep supplier assurances traceable to the exact goods.