EU RoHS Declaration Acceptance Criteria

IMPORTANT - This guideline is for information purposes only and does not constitute legal advice. This guide provides Assent’s standard checklist for reviewing inbound declarations that communicate compliance with Directive 2011/65/EU and Commission Delegated Directive (EU) 2015/863 “RoHS Directive” within the supply chain and should not be misconstrued with the requirement for Declarations of Conformity (“DoC”). The DoC guidance can be found within Annex VI of the RoHS Directive.

  1. On company letterhead. 
    • Needs to indicate that the declaration/certificate is an official company release.

  2. Includes the proper RoHS Directive legislative reference.
    • Actual legislation title: Directive 2011/65/EU of the European Parliament and of the Council of June 8, 2011 and Commission Delegated Directive (EU) 2015/863 of March 31, 2015, on the restriction of the use of certain hazardous substances in electrical and electronic equipment (“RoHS Directive”) should appear on the declaration. 
      • Other acceptable references:
        • Directive 2011/65/EU and (EU) 2015/863.
        • EU Directive 2011/65/EU and (EU) 2015/863.
        • The RoHS Directive 2011/65/EU and (EU) 2015/863.

  3. Includes a clear reference to parts or products being covered by the declaration. This can be:
    • Company level or blanket statement without individual part(s)/product(s) listing, e.g. "This declaration applies to all products sold by ABC Corporation," "This statement applies to all products produced by ABC Corporation except as listed below," etc.
      • However, parts/products that are not compliant, or that are compliant by exemption, must still be specifically identified.
    • Part-level declaration listing specific parts individually.

  4. Declares compliance status.
    • States that it does not contain substances above threshold.
    • States that it does contain substances above threshold.
      • Must identify the substance or substances creating the non-compliance per part or product.
    • States that it does contain substances above threshold with exemption.
      • Must identify the exemption and substance or substances per part or product.

  5. Declares exemption (if applicable). 
    • If any parts of products are using an exemption identified in Annex III or Annex IV of the RoHS Directive, they MUST be disclosed per part or product using the exemption.

  6. Signed by appropriate authorized representative. 
    • Name, contact details and position must be included. 
    • Must be an employee of the company issuing the declaration. 
    • Position/job title should indicate a degree of familiarity with materials or product adequate to state compliance status and seniority to bind company.
      • e.g. Engineering, Quality, Materials, Compliance Manager. 

  7. Date of reference.
    • Declaration should be no more than two years old unless:
      • There has been a change to exemption status being applied in the declaration.
      • New substances have been added to the RoHS Directive.
      • The declarant’s industry often changes materials in the production of parts covered in this declaration, in which case it should be updated upon material change.

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