What Is Global RoHS Compliance?

Global RoHS compliance means proving that electrical and electronic products do not contain restricted hazardous substances above permitted concentration limits in each market where the product is sold.

For companies, this is not only a legal checklist. It is a product data, supplier evidence and documentation challenge.

A company may need to prove:

• Whether the product is in scope
• Which substances are restricted in the target market
• Whether the product contains lead, cadmium, mercury, hexavalent chromium, flame retardants or restricted phthalates above allowed limits
• Whether any exemption is being used
• Whether supplier declarations are valid and current
• Whether technical documentation is complete
• Whether market-specific labels, declarations or conformity marks are required

In the EU, RoHS restricts hazardous substances in electrical and electronic equipment to protect human health and the environment, and the European Commission confirms that the EU RoHS framework currently restricts ten substances including lead, cadmium, mercury, hexavalent chromium, PBB, PBDE and four phthalates: DEHP, BBP, DBP and DIBP.

RoHS compliance is no longer limited to the EU. RoHS-style rules now affect product market access in many regions, including the EU, UK, China, India, UAE, Saudi Arabia, Japan, Taiwan, Korea and the EAEU.

The challenge is that these rules are not identical. Some markets restrict six substances. Others follow a ten-substance model. Some require technical files and declarations. Others focus on certification, marking, conformity assessment or website disclosure.

For companies selling electrical and electronic equipment globally, the key question is no longer:

“Is this product RoHS compliant?”

The better question is:

“Can we prove RoHS compliance for every product, supplier, material, exemption and target market?”

That proof is what customers, importers, certification bodies and market surveillance authorities may ask for.

You may need Global RoHS compliance if your company manufactures, imports, distributes or sells electrical or electronic products in more than one market.

You should assess RoHS obligations if your products include:

• Printed circuit boards
• Cables
• Connectors
• Displays
• Sensors
• Power supplies
• Batteries or battery-powered functions
• Lighting components
• Electrical tools
• Household appliances
• ICT and telecom equipment
• Industrial control equipment
• Medical or monitoring devices where applicable
• Spare parts, accessories or electronic subassemblies

The EU RoHS scope is broad because the European Commission states that all products with an electrical or electronic component must comply unless specifically excluded. The UK also confirms that its RoHS regulations cover EEE, cables and spare parts, with specific exclusions.

Most RoHS frameworks focus on hazardous substances used in electrical and electronic equipment. The exact list depends on the market.

In the UK, the official guidance lists the ten restricted substances and concentration limits, including cadmium at 0.01% and the other listed substances at 0.1%. India’s CPCB FAQ explains that RoHS under the E-Waste Rules restricts lead, mercury, cadmium, hexavalent chromium, PBB and PBDE, with 0.1% limits for most substances and 0.01% for cadmium in homogeneous materials. The UAE regulation also lists ten substances and maximum allowed ratios for electric and electronic appliances.

EU RoHS is one of the most influential RoHS frameworks globally. It applies to electrical and electronic equipment placed on the EU market unless an exclusion applies.

The EU currently restricts ten substances and aims to reduce the presence of hazardous substances in EEE, improve recyclability and protect human health and the environment.

For companies, the most important EU RoHS compliance tasks are:

• Confirm whether the product is in scope
• Identify the applicable EEE category
• Map the product BOM
• Collect supplier declarations and technical evidence
• Check whether restricted substances are present above limits
• Confirm whether any exemption applies
• Prepare technical documentation
• Issue the EU Declaration of Conformity where required
• Maintain CE marking and compliance records
• Reassess compliance when suppliers, parts or materials change

RoHS exemptions allow restricted substances to be used in specific technical applications, but only under defined conditions. They are not permanent and should not be treated as general approvals.

The European Commission explains that RoHS exemptions are limited in time and reassessed regularly, considering substitute availability, environmental and health impacts, socioeconomic impacts and potential effects on innovation.

This means companies should know:

• Which products rely on an exemption
• Which component or material uses the exemption
• Whether the exemption wording still matches the application
• Whether the exemption is still valid
• Whether a renewal or transition period affects the product
• Whether alternative materials or designs are available

A product may appear compliant at launch but become higher risk later if an exemption expires, changes or no longer matches the product’s technical use.

The UK has its own RoHS framework for Great Britain and Northern Ireland. GOV.UK guidance says in-scope products must have supporting technical documentation, a Declaration of Conformity, required labelling and the appropriate conformity marking for the GB or NI market.

The same guidance explains that GB operates its own exemptions system, while Northern Ireland continues to follow the EU exemptions system.

For businesses selling into both the EU and UK, the practical risk is assuming one file automatically covers every requirement. In reality, teams should manage EU and UK evidence separately where needed, especially for:

• Declarations of Conformity
• UKCA, CE or NI-related marking considerations
• Importer obligations
• Exemption references
• Technical file retention
• Traceability records

China RoHS is one of the most important updates for global electronics companies.

China’s national standards platform lists GB 26572-2025 as a national standard for requirements on restricted use of hazardous substances in electrical and electronic products, with an implementation date of 1 August 2027.

China’s CNCA transition announcement explains how conformity assessment standards apply during the transition period before GB 26572-2025 becomes the applicable standard from 1 August 2027.

Companies selling into China should prepare before the transition deadline by:

• Reviewing product lines sold or imported into China
• Checking supplier declarations against China RoHS requirements
• Reviewing test methods and conformity assessment evidence
• Updating product data and substance evidence
• Checking whether labels or disclosures need revision
• Coordinating compliance, quality, procurement and local market teams

Waiting until 2027 may create supplier data gaps, retesting pressure and market-access delays.

RoHS compliance is not only about avoiding restricted substances. It is about proving product compliance with reliable evidence.

For manufacturers, this means better control over materials, suppliers and product changes.

For importers, this means being able to show that the products placed on the market meet local requirements.

For distributors, this means having the right declarations and traceability records when customers or authorities ask for proof.

For procurement teams, this means selecting suppliers that can provide reliable compliance data.

For quality and regulatory teams, this means turning RoHS from a reactive document request into a controlled compliance process.

India manages RoHS obligations within its E-Waste framework. CPCB explains that producers of listed electrical and electronic equipment must ensure new EEE and related components, consumables, parts and spares do not contain specified hazardous substances above the maximum concentration values under the rules.

The CPCB FAQ also states that producers must maintain declarations on the availability of RoHS technical documents based on EN 50581 or EN IEC 63000:2018, which should be available for verification by CPCB or SPCB officials when required.

For companies, this means India RoHS should not be managed separately from E-Waste compliance. A practical India compliance program should connect:

• Product scope assessment
• Producer registration
• RoHS technical documentation
• Supplier evidence
• EPR obligations
• Portal records
• Verification readiness

The UAE has a regulation controlling hazardous substance ratios in electric and electronic devices. The UAE legislation portal lists Cabinet Resolution No. 10 of 2017 as active, and the regulation covers categories of electric and electronic devices, including large household appliances, small household appliances, IT and telecommunications equipment, consumer equipment, lighting equipment, electrical tools, toys, medical devices and monitoring equipment.

The UAE regulation lists maximum allowed ratios for ten substances, including lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and four phthalates.

For exporters and importers, UAE RoHS readiness means maintaining structured product evidence that can support conformity, certification or authority review.

Saudi Arabia has a technical regulation for the restriction of hazardous substances in electrical and electronic appliances and equipment. SASO guidance explains that the regulation is intended to ensure product safety from hazardous chemicals that may affect consumer health, safety and the environment during manufacture or disposal.

Companies selling into Saudi Arabia should treat Saudi RoHS as a local market-access requirement. A practical compliance file should support product category assessment, supplier evidence, testing where needed, technical documentation and conformity workflows.

Japan’s J-MOSS framework is different from EU RoHS because it focuses on marking and disclosure for designated products.

JEITA explains that J-MOSS is based on JIS C 0950 and sets rules for marking the presence of six specific chemical substances in seven specific electrical and electronic products. These products include personal computers, unit-type air conditioners, television sets, refrigerators, washing machines, clothes dryers and microwaves.

For companies selling into Japan, compliance teams should not only collect supplier declarations. They should also confirm whether local marking or website disclosure obligations apply.

A strong RoHS compliance file should be structured, traceable and linked to the product design.

EN IEC 63000 is important because it is the harmonised standard for technical documentation supporting assessment of materials, components and EEE under EU RoHS.

Missing supplier data is one of the most common RoHS compliance problems.

If a supplier cannot provide reliable declarations or material information, the company placing the product on the market may still carry responsibility for compliance. This creates risk for manufacturers, importers and brand owners.

Common supplier data problems include:

• Generic RoHS statements without part numbers
• Declarations that do not mention the applicable RoHS version
• Missing phthalate information
• Expired certificates
• Test reports that do not match the current part revision
• No evidence for exemptions
• Evidence that does not identify homogeneous materials
• Supplier responses stored in emails without review status
• No link between the declaration and the product BOM

When supplier data is missing, companies should use a risk-based approach:

1- Identify the affected parts and products

2- Check material and supplier risk

3- Request updated declarations or full material data

4- Review whether restricted substances may be present

5- Use testing where supplier evidence is not sufficient

6- Document the decision and keep the record in the technical file

This is where a structured compliance system becomes valuable. The goal is not to collect more documents. The goal is to collect the right documents, validate them and connect them to the right product.

Use this checklist to evaluate whether your RoHS process is ready for global market access.

Days 1–5: Identify affected products

Start with product families that contain electrical or electronic components. Prioritize products sold in multiple markets, products with complex BOMs and products using legacy components.

Days 6–10: Map target markets

Identify whether the product is sold in the EU, UK, China, India, UAE, Saudi Arabia, Japan, Taiwan, Korea, EAEU or other RoHS-style markets.

Days 11–15: Review supplier evidence

Check whether supplier declarations are current, market-specific and linked to exact part numbers and revisions.

Days 16–20: Check exemptions and high-risk materials

Review lead-containing alloys, solders, glass, ceramics, PVC materials, flame-retarded plastics, cables, coatings and other high-risk materials.

Days 21–25: Build or update the technical file

Organize BOMs, supplier declarations, full material declarations, test reports, exemption assessments, declarations and change-control records.

Days 26–30: Close gaps and assign ownership

Assign missing supplier requests, testing decisions, exemption reviews, declaration updates and market-specific labelling tasks to responsible owners.

Companies often face RoHS problems because the process is managed manually across spreadsheets, emails and PDFs.

Common mistakes include:

• Assuming EU RoHS compliance automatically covers every market
• Treating supplier declarations as permanent
• Ignoring phthalates in markets that restrict ten substances
• Not tracking exemptions and expiry dates
• Forgetting cables, spare parts and accessories
• Not linking documents to BOMs and product revisions
• Keeping test reports that do not match the current product design
• Missing UK-specific requirements after Brexit
• Not preparing for China GB 26572-2025 early enough
• Treating India RoHS separately from E-Waste obligations
• Missing local marking or disclosure requirements in Japan or UAE
• Releasing product changes without RoHS reassessment

Global RoHS compliance becomes difficult when product data, supplier documents and regulatory requirements are managed in different systems.

ComplyMarket helps companies manage RoHS requirements through a structured compliance workflow instead of scattered spreadsheets and disconnected supplier files. ComplyMarket’s Global RoHS service explains that the platform helps teams configure RoHS rule sets by market, centralize supplier declarations, test reports and exemption evidence, link evidence to BOMs and product families, manage market-specific labelling obligations, generate technical documentation packs and maintain audit trails and dashboards.

ComplyMarket’s material compliance software also supports supplier data collection, supplier risk assessment and restricted-substance compliance workflows based on accepted documentation practices such as IEC 63000.