Direct answer: A material-compliance (RoHS/REACH) page cannot just say "compliant with RoHS and REACH." It should state the products and regulations covered, the homogeneous-material basis, restricted substances and thresholds, the difference between test reports and supplier declarations, exemptions, SVHC information, China RoHS marking and EFUP, conflict minerals, report validity, and change re-assessment. Otherwise, when a customer asks for the "latest REACH declaration," the company sends the same three-year-old report again.
This guide is for sales, quality, engineering, procurement, legal, EHS, and website teams at export manufacturers in Changzhou and nearby industrial areas. It explains how to build and accept a material-compliance declaration page. Information is current to 2026-11-01. It is a review of public regulations, standards, and project practice, not legal, testing, certification, or compliance advice; specific scope, thresholds, exemptions, marking, and reporting obligations depend on the regulation, customer requirements, and professional advice.
RoHS applies to homogeneous materials, not total product weight. REACH SVHC concerns information transfer when a substance is above 0.1% w/w in an article. A test report is point-in-time evidence; a supplier declaration is an ongoing commitment—neither replaces the other.
How does the material-compliance page relate to certification, export-document, carbon-footprint, and supplier-onboarding pages?
The certification page answers which system/product certifications are held; the export-document page answers invoices, bills of lading, and certificates of origin; the carbon-footprint page answers product emissions; the supplier-onboarding page answers supplier qualifications and audits; the material-compliance page answers which substances are present, whether limits are met, which report/declaration supports it, how SVHC information is passed on, and how China RoHS marking is done. They may reference each other but cannot replace each other.
The common break is: the customer asks for a RoHS report and sales sends a three-year-old finished-product report; the customer asks for a REACH SVHC declaration and the supplier replies "none"; the China RoHS label is applied but the EFUP and hazardous-substance table do not match; material is changed without re-assessment and the old report is still in use. Stating the regulations, thresholds, report/declaration distinction, versions, and changes on the website lets sales stop hunting through quality files.
| Page/entry | Answers | Audience | Cannot replace |
|---|---|---|---|
| Certification page | System/product certifications and scope | Procurement, compliance | Substance limits and SVHC information |
| Export documents | Invoice, bill of lading, certificate of origin | Export, freight forwarders | Material-compliance declaration |
| Carbon footprint page | Product emissions, CBAM data | Customers, importers | Hazardous-substance restrictions |
| Supplier onboarding | Supplier qualifications, audits, EHS | Procurement, SQE | Finished-product compliance conclusion |
| Material-compliance page | RoHS/REACH/China RoHS/conflict minerals, reports and declarations | Customer SQE, procurement, compliance | The regulation itself or test conclusion |
This page map is editorial; EU RoHS restricted substances and homogeneous-material limits are on the European Commission RoHS page.
What material-compliance documents do customers usually request?
Common requests: EU RoHS test report/declaration, REACH SVHC declaration (with Candidate List version and threshold), SCIP information, China RoHS marking/hazardous-substance table/EFUP, conflict-minerals (3TG) declaration, PAHs/ELV/packaging compliance, SDS, and IMDS/CAMDS or IPC-1752A substance declarations. Requirements differ by customer/industry; the page should first present a matrix by product/market/customer, not one universal declaration.
The value of the matrix is telling the customer whether the requested document exists, which models it covers, which regulation version it relies on, and how often it is updated. Automotive customers may need IMDS and ELV; electronics customers may need RoHS+REACH+SCIP; electrical products exported to the EU need CE/RoHS technical files. Mapping document types to products is more credible than a page saying "environmentally compliant."
| Document | Typical content | Applicable to | Common gap |
|---|---|---|---|
| EU RoHS | 10 substances, homogeneous materials, exemptions, test/declaration | Electrical/electronic products | Finished-product report instead of homogeneous materials |
| REACH SVHC | Candidate List version, 0.1% w/w, information transfer | Articles/mixtures | Only "REACH compliant" |
| SCIP | Article ID, SVHC name/concentration/location | Placing on the EU market | Done only when asked |
| China RoHS | Marking, hazardous-substance table, EFUP, conformity assessment | Made/sold/imported in China | Marking and table mismatch |
| Conflict minerals | 3TG, smelters/refiners, due diligence | Customer/regulatory requirement | Only "conflict-free" |
| Substance declaration | IMDS/CAMDS, IPC-1752A, BOM levels | Automotive/electronics chains | BOM and declaration mismatch |
This matrix is editorial; specific document types, formats, and scope follow customer, industry, and regulatory requirements.
How should "homogeneous material" and scope be explained?
RoHS limits apply to "homogeneous materials"—single materials that cannot be mechanically separated (e.g. solder joints, pin plating, plastic housings, cable insulation)—not total product weight or an arbitrarily removed part. The page should state the products/models covered, exemptions, exceptions, and exclusions; when a customer asks "is the finished product compliant?", the answer must trace to the BOM/homogeneous-material list and test reports, not a sentence saying "the product passed."
Homogeneous material is the most disputed RoHS concept: on one PCB, solder, solder mask, plating, and substrate are different homogeneous materials; in one cable, conductor and insulation are separate; in one screw, plating and base metal are separate. If a supplier declaration says only "this product complies with RoHS" without homogeneous-material/BOM support, the customer cannot use it in a technical file or audit.
| Concept | What to state | Evidence | Common gap |
|---|---|---|---|
| Products covered | Model/series/market, exclusions | Product list | One declaration for all |
| Homogeneous material | Single material that cannot be mechanically separated | BOM/material list | Calculated on the finished product |
| Limits | Thresholds by substance (e.g. 0.1%/0.01%) | Regulation/report | Only "within limits" |
| Exemptions | Exemption clause, applicable part, expiry | Regulation annex | Expired exemption still used |
| Evidence level | Report tied to part/lot/homogeneous material | Test report | Report detached from BOM |
| Changes | Material/supplier/process change re-assessment | Change record | Old report continues |
This homogeneous-material basis is editorial; EU RoHS maximum concentrations are by weight in homogeneous materials, per the European Commission RoHS page; scope and exemptions follow the directive.
How do test reports, supplier declarations, and ongoing compliance differ?
A test report is the result for a sample/lot, by a method, at a point in time; a supplier declaration is a commitment to ongoing conformity within an agreed scope and version; neither replaces the other. A report should state the laboratory, method, sample, homogeneous material, detection limit, result, and date; a declaration should state the regulation version, part numbers, thresholds, exemptions, data source, and validity. Ongoing compliance also needs change control and periodic review.
Many companies treat a report as a permanent certificate, or treat a declaration as test data with no evidence. A workable approach: key homogeneous materials have test reports/material certificates; suppliers declare against the BOM; the finished-product maker consolidates and assesses risk; material/supplier/process changes and regulation updates trigger re-assessment. Stating these three layers on the page tells the customer which evidence they are getting.
| Evidence | What it proves | Key fields | Common gap |
|---|---|---|---|
| Test report | Sample/lot result at test time | Lab, method, sample, detection limit, date | Unrepresentative sample |
| Supplier declaration | Ongoing conformity within agreed scope/version | Regulation version, part, threshold, exemption, validity | "Compliant" with no data |
| Material certificate | Material composition/grade | Heat/lot, material, supplier | Mismatch with BOM |
| Consolidated assessment | Overall conclusion for product/series | BOM coverage, risk, exemptions | Consolidate without assessment |
| Change re-assessment | Still compliant after change | Change record, re-assessment | Old report continues |
This evidence hierarchy is editorial; test methods, report formats, and declaration templates follow customer, laboratory, and regulatory requirements.
Which substances and thresholds apply under EU RoHS?
EU RoHS currently restricts 10 substances: lead, mercury, hexavalent chromium, PBB, and PBDE at 0.1%; cadmium at 0.01%; and DEHP, BBP, DBP, and DIBP at 0.1%, by weight in homogeneous materials. Some applications have exemptions (Annex III/IV) with scope and expiry. The page should state the products covered, the 10 substances, thresholds, exemption references, and the CE/technical-file relationship—not just "RoHS 2.0 compliant."
The European Commission's RoHS page states that RoHS restricts certain hazardous substances in electrical and electronic equipment, currently ten substances, and that all products with an electrical/electronic component must comply unless specifically excluded. Cadmium's threshold is 0.01%; the other nine are 0.1%. An exemption is not "permanent and free": customer audits will check the exemption clause, applicable part, and expiry.
| Substance | Threshold (homogeneous material) | Typical location | Common gap |
|---|---|---|---|
| Lead (Pb) | 0.1% | Solder, plating, glass/ceramics | Exemption not stated |
| Mercury (Hg) | 0.1% | Lamps, switches, sensors | Only finished product tested |
| Cadmium (Cd) | 0.01% | Contacts, plating, pigments | Judged at 0.1% |
| Hexavalent chromium (Cr(VI)) | 0.1% | Zinc plating/passivation, leather | Only total chromium tested |
| PBB/PBDE | 0.1% each | Flame-retardant plastics, cables | Mixed testing |
| DEHP/BBP/DBP/DIBP | 0.1% each | Plasticisers, cable/soft parts | Four phthalates missed |
Substances and thresholds are on the European Commission RoHS page; exemptions, scope, and technical files follow the directive and professional advice.
How should REACH SVHC and SCIP be explained?
The REACH Candidate List (SVHC) is updated regularly; where an SVHC is above 0.1% w/w in an article, the supplier must provide sufficient information for safe use to customers, and consumer requests must be answered within 45 days; articles placed on the EU market may also involve SCIP information submission. The page should state the Candidate List version/date, the threshold basis (article/complex object), how information is communicated, SCIP coverage, and the update mechanism—not just "REACH compliant."
The REACH 0.1% is the concentration in the article, not in a homogeneous material; how to calculate it for complex objects/components requires judgment under the regulation and guidance. The Candidate List is updated several times a year, and customers ask for the "latest" declaration. A one-time declaration against an old list may become outdated when a new substance is added. The page should make "list version + update date + products covered + data source" mandatory fields.
| Item | What to state | Evidence | Common gap |
|---|---|---|---|
| List version | Candidate List publication date/version | ECHA list | Old declaration |
| Threshold | Above 0.1% w/w in the article | Calculation/declaration | Calculated on homogeneous material |
| Information transfer | Name, safe-use information, response deadline | Declaration/SDS | Only "no SVHC" |
| SCIP | Article ID, SVHC name/concentration/location | SCIP record | Only when asked |
| Complex objects | Component/product level, exemptions/exclusions | BOM/guidance | Basis unclear |
| Updates | List update/material/new supplier re-assessment | Change record | One declaration forever |
REACH information transfer and the 45-day consumer response are on the European Commission REACH page; SCIP and complex-object details follow the Waste Framework Directive, ECHA guidance, and professional advice.
What should China RoHS state, and what changes in 2027?
China RoHS applies to electrical/electronic products manufactured, sold, or imported in China; it restricts six substances (lead, mercury, cadmium, hexavalent chromium, PBB, PBDE), requires marking of hazardous-substance name/content/location, recyclability, and EFUP under the marking standard, and applies conformity assessment to products in the compliance catalogue. The current limit standard is GB/T 26572-2011; mandatory GB 26572-2025 was published on 2025-08-01 and takes effect on 2027-08-01, fully replacing the former—state the transition.
China RoHS is not the same as EU RoHS: China RoHS has marking, EFUP, a compliance catalogue, and conformity assessment; EU RoHS has CE, technical files, and annex exemptions. Many companies use an EU report as China RoHS evidence, or apply a "RoHS" label without the hazardous-substance table/EFUP. Separate the two on the page so customers and auditors do not mix them.
| Item | What to state | Evidence | Common gap |
|---|---|---|---|
| Scope | Electrical/electronic products made/sold/imported in China | Product list | Mixed with EU RoHS |
| Six substances | Lead, mercury, cadmium, Cr(VI), PBB, PBDE | Test/declaration | Missing items |
| Marking | Name/content/location, recyclability, impact | Label/manual | Logo only |
| EFUP | Period and marking location | Label/manual | Not marked |
| Catalogue | Whether listed; conformity assessment route | Catalogue/certificate | Not checked |
| Standard transition | GB/T 26572-2011 → GB 26572-2025 (2027-08-01) | Standard info | Unaware of new standard |
China RoHS requirements are in the Measures for the Administration of the Restriction of Hazardous Substances in Electrical and Electronic Products; the status of GB/T 26572-2011 and GB 26572-2025 is on the National Standards Information Public Service Platform.
How should conflict minerals and special customer substance requirements be handled?
Customers may require a 3TG (tin, tantalum, tungsten, gold) conflict-minerals declaration, smelter/refiner list, due diligence, or CMRT; EU Regulation 2017/821 imposes due-diligence requirements on EU importers and smelters/refiners, and the requirement flows up the supply chain. The page should state the products covered, 3TG scope, data source (CMRT/supplier declarations), smelter information, and update frequency—not just "conflict-free."
Conflict minerals is not a simple "is it in the product" question; it is supply-chain due diligence. Customers want traceable smelters/refiners and evidence, not a slogan. Beyond 3TG, automotive/electronics customers may require PAHs, ELV, PFAS, packaging materials, or RoHS exemptions; the page can list a "special customer requirements" entry, provided per project, without publishing all details.
| Requirement | What to state | Evidence | Common gap |
|---|---|---|---|
| 3TG | Tin, tantalum, tungsten, gold; products covered | CMRT/declaration | Only "conflict-free" |
| Smelters | Name, country, certification status | Supplier list | Not traceable |
| Due diligence | Policy, process, risk, correction | Report/records | No process |
| Special customer requirements | PAHs/ELV/PFAS/packaging, etc. | Project declaration | One template for all |
| Updates | Annual/supplier change/customer request | Version record | Never updated |
Conflict-minerals requirements are explained on the European Commission conflict-minerals page; specific scope, due diligence, and customer requirements follow the regulation and contract.
How should report/declaration versions, validity, and changes be controlled?
Every report/declaration should state its number, version, applicable part/model, regulation version, test/declaration date, validity or review date, laboratory/issuer, exemptions, and scope; material/supplier/process changes, regulation updates, and customer requirement changes trigger re-assessment and a new version. Mark old versions "superseded" but retain them; when a customer asks for the "latest," send the latest version of the same number, not several contradictory PDFs.
There is no universal statutory "report validity period"; it depends on the regulation, customer, material, and changes. A common approach is annual review or change-triggered re-assessment. The page should not promise "permanently valid" or "one test covers all models." Clear versions, scope, and change triggers let the customer judge whether the document can support their audit/reporting.
| Field | What to state | Evidence | Common gap |
|---|---|---|---|
| Number/version | Report/declaration number, version, date | Cover page | File name as version |
| Scope | Part/model/market/homogeneous material | BOM/list | One document for all |
| Regulation version | Directive/regulation/standard version | Reference page | Old regulation |
| Validity/review | Validity or next review date | Version record | Permanent validity |
| Change trigger | Material/supplier/process/regulation/customer | Change record | No re-assessment |
| Archive | Old version marked superseded, retained | Archive record | Old and new sent together |
Version control is editorial; report/declaration validity and re-assessment follow the regulation, customer, and laboratory/body advice—no universal period is set here.
What should the page say, and how should it link?
Include products and markets covered, the document matrix, homogeneous-material basis, test/declaration/ongoing compliance, EU RoHS 10 substances and thresholds, REACH SVHC/SCIP, China RoHS marking and standard transition, conflict minerals, versions/changes, and a request entry; link to the certification page, export-document page, carbon-footprint page, and supplier-onboarding page. The public page states rules and document types, not customer-specific BOMs, full test reports, or undisclosed formulations.
Make it a "material-compliance documents" page, not an "environmental declaration" slogan: first let the customer select documents by product/market; then state the regulation, thresholds, and evidence type; then the request process, versions, and changes; finally the compliance owner. Sales can screen requests, quality can align criteria, and customer SQE can prepare an audit against the same set.
| Module | What to write | Evidence/asset | Common gap |
|---|---|---|---|
| Products covered | Models/markets/exclusions | Product list | One declaration for all |
| Document matrix | RoHS/REACH/SCIP/China RoHS/conflict minerals/IMDS | List | Only "environmental" |
| Thresholds/basis | Homogeneous material, 0.1% w/w, exemptions | Regulation/report | Basis unclear |
| Evidence | Report/declaration/material cert/consolidation | Templates | Report treated as certificate |
| Version/change | Number, version, validity, re-assessment trigger | Version record | Old version continues |
| Request/links | Request process, contact; certification/export/carbon/onboarding | Page test | Broken links |
These modules are editorial; public scope, customer-specific data, and full reports follow confidentiality requirements and the contract.
Go-live acceptance checklist
Ten checks: products covered, document matrix, homogeneous-material basis, EU RoHS substances/thresholds, REACH SVHC/SCIP, China RoHS and standard transition, conflict minerals, evidence hierarchy, versions/changes, and links/owner. Each needs an owner, evidence, and review date. The pass condition is not "the page says RoHS/REACH compliant"; it is that the customer knows which document, which models, which regulation version, and how long it is valid.
Sales, quality, engineering, procurement, legal, EHS, and the website vendor can share this list. Before go-live, run one real customer questionnaire through the flow: customer requests RoHS+REACH+SCIP → product/part mapping → report/declaration/supplier data → version/exemption → request/issue → customer confirmation. Any step that fails is a step the page has not yet explained.
| Check | Pass condition | Evidence | If it fails |
|---|---|---|---|
| Products | Models/markets/exclusions clear | Product list | Add scope |
| Document matrix | RoHS/REACH/SCIP/China RoHS/conflict minerals/IMDS | List | Add documents |
| Homogeneous material | Basis, BOM/material list, report mapping | BOM/report | Add basis |
| EU RoHS | 10 substances, thresholds, exemptions, CE/technical file | Report/declaration | Add evidence |
| REACH | List version, 0.1% w/w, information transfer, SCIP | Declaration/record | Add declaration |
| China RoHS | Marking, hazardous-substance table, EFUP, catalogue, transition | Label/certificate | Add marking |
| Conflict minerals | 3TG, smelters, due diligence, updates | CMRT/report | Add process |
| Evidence hierarchy | Report/declaration/material cert/consolidation separated | Templates | Add templates |
| Versions/changes | Number, version, validity, re-assessment, archive | Version record | Add records |
| Links/owner | Certification/export/carbon/onboarding reachable; compliance owner named | Page test | Fix links |
This checklist is editorial; specific scope, thresholds, exemptions, marking, and reporting follow the regulation, customer requirements, and professional advice.
Who should read this, who should not, and what decisions does it support?
It suits manufacturers in Changzhou and nearby areas exporting to the EU/China in electrical/electronic equipment, automotive parts, appliances, cables, plastic parts, and products with electrical/electronic components. It does not suit teams with no electrical/electronic components whose customers require no substance declarations, such as pure structural parts or raw materials.
Read it if you are in sales, quality, engineering, procurement, legal, EHS, or a website vendor; you are building a material-compliance page, RoHS/REACH declarations, customer questionnaires, IMDS/SCIP, or China RoHS marking; or you need to decide which regulations apply, which basis to use, whether to provide a report or declaration, how to mark exemptions, and how to update versions. Skip it if you use a finished-product report as homogeneous-material evidence; you replace data and declarations with "RoHS/REACH compliant"; or you want one page to replace regulatory, testing, or legal advice. It supports self-review of products, document matrix, homogeneous materials, EU RoHS, REACH, China RoHS, conflict minerals, evidence hierarchy, and versions.
Lingyi Information is a website development and enterprise AI project provider, not a testing body, certification body, law firm, or compliance consultant. This article is not a substitute for legal, testing, certification, or compliance advice. Changzhou projects are delivered remotely or on site as confirmed per project; Lingyi is one candidate, does not claim a local office or team, and does not promise compliance conclusions, customer conversion, or inquiries.
FAQ
Does a RoHS report have an expiry date?
There is no universal statutory validity period. A report proves a sample/lot result at test time; continued validity depends on material, supplier, process, regulation, and customer requirements. A common approach is annual review plus change-triggered re-assessment. Do not write "permanently valid"; state the report number, applicable part/homogeneous material, date, and review mechanism.
How is the REACH SVHC 0.1% calculated?
The REACH 0.1% w/w generally refers to the concentration of an SVHC in an article, not the RoHS homogeneous-material basis; complex objects/components require judgment under the regulation and guidance. Above the threshold, the supplier must provide sufficient safe-use information to customers, and consumer requests must be answered within 45 days. Specific calculation and communication follow the regulation, ECHA guidance, and professional advice.
Is China RoHS the same as EU RoHS?
No. EU RoHS covers 10 substances, homogeneous-material limits, CE/technical files, and annex exemptions; China RoHS is the Measures for the Administration of the Restriction of Hazardous Substances in Electrical and Electronic Products, requiring six-substance restrictions, marking, hazardous-substance table, EFUP, compliance catalogue, and conformity assessment. They cannot replace each other; reports/declarations should be separate.
What if a customer asks for SCIP/IMDS?
Confirm the product and market first: SCIP concerns articles placed on the EU market containing Candidate List SVHCs above 0.1% w/w; IMDS is the automotive substance-data system. The page can say "available per project," but do not promise ready data for all products; it requires BOM, supplier declarations, and substance data. If data is missing, fill the supply chain—do not invent it.
Are conflict minerals mandatory?
Depends on the customer/market/regulation. EU Regulation 2017/821 imposes due-diligence requirements on EU importers and smelters/refiners, and customers flow the requirement upstream; even if not directly applicable, customers may require CMRT/smelter lists. State the products, 3TG scope, data source, and updates—not just "conflict-free."
What if a supplier will not provide a declaration?
Risk-tier first: key homogeneous materials/high-risk suppliers need reports or declarations; if unavailable, supplement with testing/third-party data or change suppliers. The page can say "documents provided per project," but "the supplier did not provide it" cannot become "we guarantee compliance." Disclose missing data honestly; do not cover it with a universal template.
One-sentence takeaway
A Changzhou manufacturer's material-compliance (RoHS/REACH) page should not say "environmentally compliant." It should turn products covered, document matrix, homogeneous-material basis, EU RoHS 10 substances/thresholds, REACH SVHC/SCIP, China RoHS and the 2027 standard transition, conflict minerals, evidence hierarchy, and versions into a verifiable checklist—so the customer knows which document, which models, and which regulation version.
Method and limitations
This is a review of public regulations, standards, and project practice, not a compliance certification or legal opinion on any company, product, material, test, certification, or report. No undisclosed customer BOMs, formulations, test reports, or supply-chain data were used. The document matrix, threshold basis, evidence hierarchy, version fields, and acceptance checklist are editorial suggestions, not legal, testing, certification, or compliance conclusions. Specific scope, thresholds, exemptions, marking, reporting, and customer requirements depend on the regulation, contract, customer requirements, and professional advice.
Sources and scope
Information is current to 2026-11-01. The following are public official/primary pages; their scope, version, and wording control.
- European Commission, RoHS Directive (Directive 2011/65/EU): European Commission. Ten restricted substances; cadmium 0.01%, the others 0.1% by weight in homogeneous materials; scope and exemptions follow the directive.
- European Commission, REACH Regulation (Regulation (EC) No 1907/2006): European Commission. SVHC information transfer and the 45-day consumer response; Candidate List and SCIP obligations follow ECHA guidance and the Waste Framework Directive.
- Measures for the Administration of the Restriction of Hazardous Substances in Electrical and Electronic Products (Order No. 32 of MIIT and seven other departments, effective 2016-07-01): gov.cn. Six hazardous substances, marking, EFUP, compliance catalogue, and conformity assessment.
- GB/T 26572-2011, Requirements of concentration limits for certain restricted substances in electrical and electronic products (current), and GB 26572-2025, Requirements for the restriction of hazardous substances in electrical and electronic products (published 2025-08-01, effective 2027-08-01, fully replacing GB/T 26572-2011): National Standards Information Public Service Platform.
- European Commission, Conflict Minerals Regulation (Regulation (EU) 2017/821) explained: European Commission. 3TG due diligence and obligations of EU importers/smelters/refiners; specific scope follows the regulation.