RoHS Compliance Consulting - The 3TGs
EU Directive 2011/65/EU

RoHS

Restriction of Hazardous Substances

RoHS restricts the use of specific hazardous substances in electrical and electronic equipment sold in the European Union. Originally targeting six substances, the directive was expanded under RoHS 2 to include four phthalates, bringing the total to ten restricted substance groups. Compliance is mandatory before any EEE product can be placed on the EU market.

Live Reporting Snapshot

A snapshot of the live reporting dashboard our clients receive.

0%
Substance Coverage
All 10 RoHS substances screened per engagement
0%
Exemption Flag Rate
Products utilizing at least one active exemption
0%
Supplier Declaration Rate
Valid RoHS data received across active programs
0+
Material Declarations
Homogeneous material declarations processed
Substance Coverage by Group
Supplier Declaration Status
Declaration Completeness Trend

RoHS Declarations & EU Conformity Documentation

We deliver complete RoHS compliance packages including substance screening at the homogeneous material level, EU Declarations of Conformity, and technical documentation files maintained for the required 10-year retention period.

Full Substance Screening

Product-level screening against all 10 RoHS restricted substances, measured at the homogeneous material level to meet threshold requirements precisely.

Supplier Data Collection & Validation

End-to-end supplier data collection and validation campaigns - from outreach through receipt, review, and gap closure across your supply chain.

Lab Testing Coordination

Coordination of third-party lab testing when supplier declarations are insufficient or unavailable - ensuring your technical file stands up to market surveillance scrutiny.

EU DoC & Technical File Packaging

EU Declaration of Conformity drafting and technical documentation packaging maintained for the mandatory 10-year post-market retention period.

Who It Applies To

Manufacturers, importers, and distributors of electrical and electronic equipment sold in the EU. RoHS covers 11 product categories - from large household appliances and IT equipment to medical devices and monitoring instruments. If your product uses electricity to function and is sold in the EU, RoHS almost certainly applies.

Large Household Appliances
Small Household Appliances
IT & Telecommunications
Consumer Equipment
Lighting Equipment
Electronic & Electrical Tools
Toys & Leisure Equipment
Medical Devices
Monitoring Instruments
Automatic Dispensers
10
Restricted Substance Groups
11
Product Categories Covered
10yr
Document Retention Period
0ppm
Tolerance for Non-compliance

Key Requirements

RoHS compliance is not a one-time exercise. It requires ongoing substance monitoring, document maintenance, exemption tracking, and supply chain engagement. These are the non-negotiable obligations for any EEE placed on the EU market.

  1. Maximum Concentration Values (MCVs): Products must not exceed the threshold for any of the ten restricted substances, measured per homogeneous material - not per component or product.
  2. EU Declaration of Conformity: An EU DoC must be prepared and kept available to market surveillance authorities for the full 10-year retention window.
  3. Technical Documentation: Full technical documentation - including test reports, supplier declarations, and substance data - must be maintained for 10 years after market placement.
  4. CE Marking: CE marking is required for all compliant EEE products. Incorrect or unsupported CE marks create liability exposure across the distribution chain.
  5. Exemption Tracking: Applicable exemptions must be actively monitored. They are time-limited and subject to renewal or withdrawal, and reliance on an expired exemption invalidates compliance.

Restricted Substances & Limits

All thresholds are measured per homogeneous material - not per product or component. This distinction is the source of most screening failures in the field.

Pb
Lead
0.1% (1,000 ppm)
Hg
Mercury
0.1% (1,000 ppm)
Cd
Cadmium
0.01% (100 ppm) Stricter threshold
Cr6+
Hexavalent Chromium
0.1% (1,000 ppm)
PBB
Polybrominated Biphenyls
0.1% (1,000 ppm)
PBDE
Polybrominated Diphenyl Ethers
0.1% (1,000 ppm)
DEHP
Di(2-ethylhexyl) Phthalate
0.1% (1,000 ppm) Added under RoHS 2
BBP
Benzyl Butyl Phthalate
0.1% (1,000 ppm) Added under RoHS 2
DBP
Dibutyl Phthalate
0.1% (1,000 ppm) Added under RoHS 2
DIBP
Diisobutyl Phthalate
0.1% (1,000 ppm) Added under RoHS 2

Where Programs Break Down

01
Confusing product-level compliance with homogeneous material-level thresholds - the most frequent cause of invalid declarations.
02
Relying on expired exemptions that have lapsed or are under active review - without any internal tracking or alert mechanism in place.
03
Not maintaining technical documentation for the required 10-year retention period - leaving the organization exposed during market surveillance audits.
04
Accepting supplier RoHS certificates at face value without verifying the underlying substance-level data or the certificate's scope of applicability.
05
Missing the four phthalates added under RoHS 2 - DEHP, BBP, DBP, and DIBP - which are still routinely omitted from older supplier questionnaires and declarations.
06
Failing to track RoHS product category scope changes that may bring previously exempt product lines into compliance scope as the directive evolves.

How The 3TGs Helps

Product scope assessment to determine which of the 11 RoHS categories applies - and whether your product qualifies for any category-level exclusions.
Substance threshold evaluation at the homogeneous material level - ensuring your screening methodology matches what regulators and auditors actually require.
Exemption applicability reviews and expiry tracking - identifying which exemptions apply to your specific use cases and flagging renewal windows before they close.
EU Declaration of Conformity preparation - drafted to the correct format, referencing the applicable directive, standards, and conformity route.
Technical documentation packaging for the 10-year post-market retention period - organized to withstand market surveillance requests without preparation time.
Supplier RoHS data collection and validation campaigns - from questionnaire design and outreach through data review, gap closure, and declaration sign-off.
Lab testing coordination when supplier data is insufficient - managing test house selection, sample submission, and results integration into the technical file.

Need RoHS Compliance Support?

We handle everything from scope assessment through Declaration of Conformity - fixed fees, audit-ready outputs, and direct access to an experienced compliance consultant on every engagement.

Contact Us
207 Regent Street, Third Floor, Suite 8, London W1B 3HH
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