✅ What you must be able to prove (global baseline)

To sell electrical/electronic products into RoHS markets, you typically need to prove:

• Substance limits by homogeneous material (not only by part number)
• Evidence-backed compliance (supplier declarations + testing when needed)
• Correct exemption use (scope + justification + expiry tracking under regimes that use exemptions)
• Correct market labeling/marking
• Inspection-ready technical documentation (traceable and reproducible)

 

🧪 Restricted substances: “6” vs “10”

 

Common “6 substances”

EU RoHS restricts the classic six: Pb, Hg, Cd, Cr⁶⁺, PBB, PBDE.

 

EU “10 substances” (adds phthalates)

EU added four phthalates (DEHP, BBP, DBP, DIBP) via Delegated Directive (EU) 2015/863.

Practical impact: plastics, cables, soft polymers, and adhesives often become the highest-risk material set once phthalates apply.

 

🗺️ Global RoHS versions: what changes by market

EU RoHS

• Legal basis: Directive 2011/65/EU + amendments.
• Documentation: EN IEC 63000 is widely used to structure RoHS technical documentation and is referenced as the current harmonised standard in EU evaluation materials.

 

UK RoHS

• Legal basis: Restriction of the Use of Certain Hazardous Substances in EEE Regulations 2012 (as amended).
• Guidance: UK business guidance is maintained by OPSS on GOV.UK (useful for role mapping: manufacturer/importer/distributor).

 

China RoHS

• Framework: “Administrative Measures…” (often called China RoHS 2 / MIIT Order 32).
• Labeling rule: SJ/T 11364-2024 introduces updated hazardous substance information/labeling approaches and became effective April 1, 2025 per industry compliance bulletins.
  (China is frequently failed due to disclosure/labeling execution, not substance thresholds.)

 

 

Korea (K-RoHS under EEEV Act)

• Korea controls hazardous substances through the Act on Resource Circulation of Electrical and Electronic Equipment and Vehicles (EEEV Act).

 

India (RoHS controls under E-Waste Rules)

• India’s E-Waste (Management) Rules 2022 include Rule 16 (“Reduction in the use of hazardous substances…”) requiring producers to ensure new EEE does not exceed listed substance limits.

 

Japan (J-MOSS / JIS C 0950)

• Japan’s J-MOSS (JIS C 0950) is a marking-for-presence approach for specified product categories and substances (commonly referenced as “Japanese RoHS”).

 

UAE RoHS

• UAE Cabinet Resolution No. (10) of 2017 sets the UAE RoHS scheme for controlling hazardous substance ratios in electrical/electronic devices.

 

EAEU “RoHS” (TR EAEU 037/2016)

• TR EAEU 037/2016 restricts hazardous substances in electrotechnical and radio-electronic products placed on the EAEU market.

 

Turkey RoHS

• Turkey published a RoHS-style regulation restricting hazardous substances in EEE (aligned conceptually with EU RoHS).

 

🧩 What a company must do to comply (multi-market RoHS program)

 

1) 🎯 Define target markets + scope per SKU

• Build a SKU-to-market matrix (EU, UK, China, Korea, India, Japan, UAE, EAEU, Turkey, etc.)
• Confirm in-scope categories and exclusions (don’t assume identical scope).

 

2) 🧱 Control configurations and BOMs

• Lock product variants (model, options, region-specific parts)
• Identify high-risk materials (PVC, soft polymers, coatings, solders)

 

3) 📥 Collect supplier evidence that is usable in audits

Minimum evidence pack per part/material:

• Supplier material declaration (standard format where possible)
• Restricted substance statement aligned to the applicable “6/10” list
• Exemption claim (if used) with exact exemption reference + applicability statement (EU-style regimes).

 

4) 🧪 Use risk-based testing to close evidence gaps

• Screen high-risk materials/components
• Do confirmatory lab testing when supplier evidence is weak or risk is high

 

5) 📁 Build technical documentation (market-ready)

• Keep a technical file that can be reproduced for any SKU and supplier lot
• Structure EU-style documentation using recognized approaches (commonly aligned to EN IEC 63000).

 

6) 🏷️ Implement market labeling/marking correctly

• Separate “product compliant” from “labeling compliant”
• China/Japan/UAE often require specific disclosures/marking steps.

 

7) 🔁 Enforce change control (PCNs/alternates)

• Any supplier/AVL/BOM change triggers a RoHS impact check
• Alternate parts must be approved with evidence before use

 

8) 📅 Maintain a regulatory update cadence

• EU lists/exemptions evolve; China labeling standards update; UK guidance changes—your program needs periodic review.

 

📁 Inspection-ready checklist (what you should have on hand)

✅ SKU/configuration definition + controlled BOM

✅ Part/material evidence mapping (supplier declarations + traceability)

✅ Test reports (where used) + sampling rationale

✅ Exemption register (where applicable) with expiry and scope control

✅ Market labeling proofs (artwork, manuals, hazardous substance tables where required)

✅ Technical documentation pack (organized, versioned, reproducible)

 

📦 Service deliverables

• 🗺️ Global RoHS applicability & version map (by market and product family)
• 🧪 Restricted substances matrix (“6 vs 10” and market overlays)
• 🧾 Supplier evidence request pack (templates + acceptance criteria)
• 🔗 BOM-to-evidence traceability model (SKU → part → material → evidence)
• 🧩 Exemption governance pack (where applicable)
• 🏷️ Labeling/marking checklist (China/Japan/UAE/EAEU focused)
• 📁 Technical documentation outline aligned to EU-style expectations

 

❓ FAQ

Do we need testing for every product?
Not always. Strong supplier evidence + controlled change management can reduce testing. Testing is typically used to close gaps and manage high-risk materials.

Can one declaration cover all markets?
Usually no. You can build one evidence core and generate market-specific outputs (especially for labeling/marking differences).

 

⭐ Why ComplyMarket for Global RoHS Versions

ComplyMarket is an integrated compliance management and reporting platform that helps teams manage global RoHS version requirements through a structured, audit-ready workflow—rather than relying on scattered PDFs and spreadsheets.

With ComplyMarket you can:

• 🗺️ Configure RoHS rule-sets by market (EU/UK/China/Korea/India/Japan/UAE/EAEU/Turkey)
• 🧾 Centralize supplier declarations, test reports, and exemption evidence in a controlled library
• 🔗 Link evidence directly to BOMs, parts, materials, SKUs, and product families for fast customer/regulator responses
• 🏷️ Manage market-specific labeling/marking obligations with structured checklists and controlled outputs
• 📁 Generate technical documentation packs aligned to accepted RoHS documentation practices (including EN IEC 63000-style structuring)
• 🔁 Enforce change control workflows so AVL/PCNs trigger reassessment before shipment
• 📊 Maintain audit trails and dashboards that make multi-market RoHS compliance faster, cleaner, and lower-risk

For companies shipping to multiple regions, ComplyMarket is an exceptional, end-to-end solution to comply with Global RoHS Versions—and to keep compliance valid as products and regulations change.