RoHS: restricted substances and supplier evidence

• "RoHS compliance collection" supplier questionnaire
• Material assessment grid: scope, substances and analytical evidence
• Management of EEE out-of-scope status declared by the supplier
• Renewal campaigns for RoHS certificates

Regulatory framework

The RoHS directive (2011/65/EU) restricts the use of certain hazardous substances in electrical and electronic equipment (EEE). For purchases of components, connectors, cables or materials that go into an EEE product, RoHS due diligence is a condition for placing products on the market, not just a supplier certificate.

Lead, mercury, cadmium, hexavalent chromium and certain brominated flame retardants are capped. Exemptions exist but must be identified, dated and tracked over time.

What the buyer must require

Evidence needs to be verifiable, dated and tied to a specific reference. A generic statement isn't enough.

• RoHS declaration of conformity per reference, with documented EEE scope.
• XRF analysis or lab report dated less than 12 months ago for sensitive references.
• List of RoHS substances present and exemptions claimed, if applicable.
• Up-to-date materials BOM in case of a supplier or formulation change.

Manage compliance over time

Suplylot's RoHS questionnaire distinguishes between in-scope components and out-of-scope EEE items. Renewal campaigns ensure evidence doesn't silently age in a frozen supplier file.

• Flag "not applicable" for out-of-scope materials with a traceable justification.
• Consolidate DoC, lab reports and certificates in a file per reference.
• Cross-check RoHS and REACH for substances covered by both frameworks.

Useful sources

European Commission : RoHS Directive

EUR-Lex : Directive 2011/65/EU