1. Introduction to ROHS Certification

ROHS (Restriction of Hazardous Substances) is the "Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment", originating from the European Union. It aims to protect human health and the ecological environment by restricting the use of hazardous substances in electrical and electronic products. The directive was first issued in 2003 (2002/95/EC) and has undergone multiple revisions and upgrades. Currently, the latest valid version is ROHS 2.0 (2011/65/EU) and its subsequent amendment (EU) 2015/863.

Compared with the initial version, the most significant changes in ROHS 2.0 are the expansion of the scope of controlled products and the increase in the types of restricted substances. The control scope has expanded from the original 8 categories of electrical and electronic products to all electrical and electronic equipment except for special exemptions, including medical devices, monitoring equipment, and cables and other components; the number of restricted substances has also increased from the initial 6 to 10, with 4 newly added phthalate substances further raising the environmental protection requirements for products. As of 2025, the ROHS directive has become one of the most influential environmental compliance standards in the global electrical and electronic industry, and has been referenced and adopted by many countries and regions.

2. Introduction to ROHS Certification Marking

As part of the EU CE certification, ROHS certification's compliance mark is closely integrated with the CE mark. According to the requirements of ROHS 2.0, products that comply with the ROHS directive must bear the CE mark, indicating that the product meets multiple EU regulatory requirements including ROHS.

The CE mark is circular, composed of the letters "C" and "E", and is usually affixed to the product itself, packaging, or user manual. In the context of ROHS compliance, the use of the CE mark must comply with the following requirements:

• Producers must ensure that the product has passed ROHS testing and that technical documents (such as test reports, conformity declarations) are complete and available for inspection;

• The size of the CE mark shall not be less than 5mm, with clear and non-fading字迹;

• If the product also involves other EU directives (such as EMC, LVD), the CE mark indicates that the product fully complies with all applicable directives.

Note: There is no exclusive mark for standalone ROHS certification. Its compliance is proven by the CE mark and relevant technical documents. Purchasers usually require suppliers to provide ROHS test reports or conformity declarations as evidence.

3. Significance of ROHS Certification for Enterprises

For electrical and electronic enterprises, obtaining ROHS certification is not only a "passport" to enter the international market but also an important guarantee for the sustainable development of enterprises. The specific significance is reflected in the following three aspects:

1. Breaking Trade Barriers and Expanding the Global Market

The EU is an important consumer market for electrical and electronic products globally. ROHS 2.0 has listed CE-RoHS certification as a mandatory requirement for products to enter the EU. After passing the certification, enterprise products can smoothly enter 27 EU countries and EEA (European Economic Area) countries, and at the same time, can improve market competitiveness in other regions that recognize the ROHS standard (such as China, Japan, South Korea, etc.).

2. Enhancing Brand Image and Strengthening Customer Trust

In the current era of increasing environmental awareness, ROHS compliance has become an important consideration for consumers and purchasers when choosing products. Enterprises that have passed the certification can convey the signal of "green production and responsible operation" to the market, effectively enhance brand reputation, and strengthen cooperation viscosity with customers (especially multinational enterprises).

3. Reducing Compliance Risks and Controlling Production Costs

The EU implements a strict market supervision mechanism for ROHS compliance. Products that do not meet the requirements may face risks of recall, fines, or even market ban. Passing the certification in advance can help enterprises avoid such risks, and at the same time promote enterprises to optimize supply chain management, control the use of hazardous substances from the source, and reduce additional costs caused by material replacement or rework.

4. ROHS Certification Process

The ROHS certification process mainly includes product evaluation, testing, technical document preparation, and conformity declaration. The specific steps are as follows:

1. Product Classification and Material Sorting: Enterprises first need to clarify whether the product belongs to the scope of ROHS 2.0 control (such as medical devices, monitoring equipment, etc., need to confirm whether the transition period has passed), and sort out the list of all parts and raw materials of the product, and identify materials that may contain hazardous substances (such as solder, plastic plasticizers, etc.).

2. Selecting an Accredited Testing Institution: Choose a testing institution with CNAS (China National Accreditation Service for Conformity Assessment) or EU notified body qualifications to ensure that the test report has international recognition. Common authoritative institutions include SGS, TÜV, Intertek, etc.

3. Sample Submission and Testing Analysis: Submit representative samples according to product characteristics. The testing institution conducts testing using methods such as X-ray fluorescence spectroscopy (XRF) and gas chromatography-mass spectrometry (GC-MS) in accordance with the ROHS 10-item substance limit requirements (see the "Relevant Standards and Directives" section for details).

4. Rectification and Re-inspection (if necessary): If the test results exceed the limits, the enterprise needs to replace the unqualified materials or optimize the process, and then re-submit for inspection until it meets the requirements.

5. Compiling Technical Documents and Conformity Declaration: Enterprises need to organize technical documents such as test reports, material lists, and product manuals, and sign the EC Declaration of Conformity (DoC), declaring that the product meets the requirements of the ROHS 2.0 directive.

6. Affixing the CE Mark and Market Access: After completing the above steps, the product can be affixed with the CE mark to enter the EU market. At the same time, the technical documents must be retained for at least 10 years for inspection by EU regulatory authorities.

5. Relevant Standards and Directives

The core basis for ROHS certification is a series of directives and harmonized standards issued by the EU, mainly including:

1. Core Directives

• 2011/65/EU (ROHS 2.0): Replaced 2002/95/EC, came into effect in July 2011, and was transposed into EU member states' national laws in January 2013. Its main contents include expanding the control scope, incorporating ROHS into the CE mark system, and introducing a market supervision mechanism.

• (EU) 2015/863: An amendment to ROHS 2.0, issued in June 2015 and transposed into member states' laws in December 2016. It added restriction requirements for four phthalate substances: DEHP, BBP, DBP, and DIBP, increasing the number of controlled substances to 10.

2. Restricted Substances and Limits

3. Harmonized Standards

The EN standards issued by the EU provide technical basis for ROHS testing, such as:

• EN 62321 Series: Specifies the testing methods for hazardous substances in electrical and electronic products, including XRF screening, GC-MS quantitative analysis, etc.

6. Precautions

Enterprises need to pay attention to the following key points during ROHS certification and compliance management:

• Pay Attention to Exemption Clauses and Transition Periods: The ROHS directive has exemption clauses for some products (such as medical devices, aerospace products), and different types of products have different control transition periods (such as medical devices have been fully controlled since July 22, 2021). Enterprises need to query the official EU announcements in a timely manner to confirm whether their products are applicable to exemption or transition period policies.

• Supply Chain Management is the Core: The ROHS compliance of products depends on the materials provided by upstream suppliers meeting the requirements. Enterprises should establish a supplier audit mechanism, require suppliers to provide ROHS test reports for materials, and conduct regular sampling re-inspection to avoid the entire batch of products being non-compliant due to a single unqualified material.

• Retention and Update of Technical Documents: The EU requires enterprises to retain ROHS-related technical documents for at least 10 years, including test reports, conformity declarations, material lists, etc. If the product design or materials change, the compliance must be re-evaluated and the documents updated.

• Beware of Market Supervision Risks: EU member state customs and market supervision agencies will randomly inspect products entering the market. Once non-compliance with ROHS requirements is found, measures such as recall and fines will be taken, and it will be reported to the EU RAPEX system, which will have a negative impact on the enterprise's brand.

• Pay Attention to Regulatory Updates: The ROHS directive is under continuous revision. For example, in 2021, discussions on adding four more substances to control were held. Enterprises need to track regulatory changes through industry associations, certification bodies and other channels, and make compliance preparations in advance.

Special Reminder: ROHS certification is not a "one-time effort". Enterprises need to establish a long-term compliance management mechanism, regularly audit products and supply chains, and ensure continuous compliance with the latest regulatory requirements.