RoHS 10 Restricted Substances and Existing Reports

Evidence before conclusion：Pass does not automatically establish scope and traceability

RoHS restricts ten Annex II substances in EEE placed on the EU market: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP. Most limits are 0.1% by weight in homogeneous material; cadmium is 0.01%. Check explicit ten-substance coverage before reading Pass.

An existing report can sit within technical documentation only if it maps to part number, revision, sample and material. After a design, formulation, supplier or specification change, an old report may no longer support series-production conformity.

Bottom line first

A six-substance report is not current ten-substance coverage.
Concentrations are judged in homogeneous material.
Reports must map to actual parts and revisions.
Testing does not replace manufacturer responsibility.
Exemptions need application and date checks.

Information needed before deciding

Pb: 0.1%
Hg: 0.1%
Cd: 0.01%
Cr(VI): 0.1%
PBB: 0.1%
PBDE: 0.1%
DEHP: 0.1%
BBP: 0.1%
DBP: 0.1%
DIBP: 0.1%
Values are by weight in homogeneous material.
Technical documentation and EU DoC are retained for ten years.

Practical decision flow

Confirm scope

Determine whether the product is in-scope EEE.

Check all ten

Confirm the four phthalates are not omitted.

Map parts

Connect model, part number, revision, material and sample.

Check material level

Use homogeneous material, not product average.

Review changes

Check design, supplier and formulation changes.

What different evidence can support

Evidence	What it can support	Important limitation
RoHS test report	Results for the identified tested sample within its stated analytical scope.	It cannot alone prove series-product conformity if sample, revision or substance scope is unclear.
Supplier declaration of conformity	A supplier’s compliance claim for an identified part, material or revision.	Cross-check it against product identity, substance scope and version records.
BOM and material declaration	The mapping of parts, materials, part numbers and product structure.	It does not itself establish analytical results for every material.
Technical documentation	The evidence chain joining testing, material data, risk decisions, exemptions and change control.	It must be maintained when the product or supply chain changes.
EU declaration of conformity	The manufacturer’s formal responsibility for applicable RoHS conformity.	It does not replace traceable underlying evidence.
Sample and product traceability record	The connection between a tested sample and actual model, part number, batch or revision.	It cannot replace information about material scope or analytical method.

Common mistakes

Mistake：Read only six-substance Pass.

**Risk：**Phthalates missed.

**Better approach：**Check all ten.

Mistake：Use whole-product average.

**Risk：**Local exceedance hidden.

**Better approach：**Assess homogeneous material.

Mistake：Match only supplier name.

**Risk：**Revision mismatch.

**Better approach：**Match part and revision.

Mistake：Treat report as DoC.

**Risk：**Manufacturer duties omitted.

**Better approach：**Build full technical file.

Mistake：Call a part exempt generally.

**Risk：**Application/date may fail.

**Better approach：**Record Annex entry.

Company action checklist

Inventory ten-substance coverage.
Map report to BOM.
Flag high-risk materials.
Review supplier changes.
Verify exemptions.
Retain technical file.

Manager summary

Existing reports can reduce needless retesting only when they demonstrate ten-substance coverage and map to the real part, homogeneous material and production revision. The management priority is traceability, change control and exemption checking—not collecting more Pass labels.

Frequently asked questions

Does RoHS contain six or ten substances?

Annex II currently lists ten.

Is every limit 0.1%?

Cadmium is 0.01%; the others are generally 0.1%.

Do reports automatically expire?

There is no universal expiry date; assess current product mapping.

Is a third-party certificate mandatory?

The Directive focuses on demonstrable technical documentation.

Does CE replace evidence?

No; the technical file must still demonstrate conformity.

Official legislation and reference material

Directive 2011/65/EU (consolidated): Articles 3, 4, 7, 13, 16 and Annex II

European Union

Legal status: Consolidated EU legislative text; consult the Official Journal for authentic acts.
Last checked: 2026-08-08
Publication / update date: 2026-07-01 (current consolidation)
Used for: problem, decisionData, workflow, evidence, faqs

Commission Delegated Directive (EU) 2015/863

European Commission

Legal status: EU delegated directive amending RoHS Annex II.
Last checked: 2026-08-08
Publication / update date: 2015-06-04 (Official Journal publication)
Used for: decisionData, quickConclusion

Commission Implementing Decision (EU) 2020/659