Key takeaways
- RoHS works by homogeneous material and REACH works on the article as supplied, so one declaration cannot answer both questions.
- A usable declaration names the part, the revision, the substance list date and the legal entity that issued it.
- Full material disclosure, an SVHC statement and a declaration of conformity are three different documents with different depth.
- The file is only complete when every line of the bill of materials has evidence behind it, not just the finished assembly.
What a declaration is for
RoHS and REACH declarations arrive in the same supplier pack, are filed in the same folder and are often read in the same minute. They answer different questions. One restricts a short list of substances in electrical and electronic equipment. The other regulates chemicals more broadly and, for articles, centres on substances of very high concern.
A declaration is a statement by a supplier about a named part, at a named revision, against a named list of substances at a named date. Remove any one of those qualifiers and the statement stops being useful. The buyer's work is not collecting the document. It is checking that the document describes the part that will actually ship, from the material that will actually be used.
RoHS: ten substances by homogeneous material
RoHS restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, two brominated flame retardants and four phthalates. The limits apply by weight in each homogeneous material. A coating, a plating, a solder joint and a moulded housing are assessed separately, not as an average of the finished part.
Homogeneous material is the phrase that decides most arguments. A brass terminal with a tin plating is two materials, not one. The brass may comply while the plating does not, and an average across the part can look comfortable while one layer is over the limit. Ask for the composition by material, not a single sentence about the part.
REACH: the article and the candidate list
REACH covers substances, mixtures and articles, and it is much wider than a list of ten. For an article, the duty that reaches most buyers is the check for substances of very high concern. The threshold is 0.1 per cent by weight of the article as supplied, not of the homogeneous material.
That boundary is the opposite of the RoHS logic, which is why the same part can pass one test and still need a statement under the other. The candidate list is updated, so every statement needs the date of the list it was checked against. A statement dated before the most recent update is not necessarily wrong, but it is incomplete until it has been reviewed.
The declarations you will actually receive
Suppliers use the same words for documents of very different depth. A declaration of conformity, an SVHC statement and a full material disclosure can all arrive titled as a compliance certificate. Ask which one you are being given before you decide what it proves.
The table sets out what each document typically states and what it leaves open. The pattern is consistent: the shorter the document, the more it relies on the supplier's own file, which the buyer may never see.
| Declaration | What it states | What it leaves open |
|---|---|---|
| RoHS declaration of conformity | The part meets the restrictions for its equipment category, assessed by homogeneous material | Which exemptions are claimed, and whether the evidence is test data or material data |
| REACH SVHC statement | Whether a candidate list substance is present above 0.1 per cent of the article, with the list date | Substances added after that date, and how the concentration was calculated |
| Full material disclosure | The composition of each material in the part, usually to a declared reporting threshold | Process chemicals, packaging and substances below the reporting threshold |
A declaration answers the question it was written for. Read the scope before you file it.
What a declaration does not cover
A declaration covers the part as defined in its scope. It rarely covers everything a buyer assumes, and the gaps are predictable enough to check every time.
None of these gaps makes a declaration dishonest. They mark the edge of what it was written to do, and each one has a separate question that belongs in the supplier pack.
- Process chemicals: cutting oils, cleaners, lubricants, resists and marking fluids used during manufacture.
- Packaging and labelling: usually a separate regime with its own declaration and its own limits.
- Sub-components bought by the supplier: they can sit inside a finished part declaration with no evidence behind them.
- A candidate list update after the date printed on the statement.
- Finish performance: plating thickness, adhesion and corrosion resistance are not substance declarations.
- The route actually used: a declaration written for one plating line may not describe a second line added later.
Following the chain down the bill of materials
A declaration for an assembly is only as strong as the declarations behind its parts. The assembler may never handle the material that carries the risk, so the evidence has to travel up the chain from each sub-supplier to the part number that ships.
Map the bill of materials to the declarations you hold. Any line with no declaration is a gap, even if the finished part is declared compliant. For bought-in parts, ask for the sub-supplier name and the declaration reference, not just a statement that the sub-supplier is approved.
Family declarations are common and can be legitimate, but the link from the part to the family has to be written down. A family name on a certificate and a part number on a drawing are not the same evidence. When the family is broad, ask what the members share: the same base material, the same plating route and the same production site are a reasonable basis. A shared brand name is not.
Checking a declaration before you file it
Read the declaration as an auditor would. The check takes minutes when the file is complete and a week when it is not, so it is worth doing at the start of a programme rather than at the end of an audit.
- Part number and revision match the drawing and the purchase order.
- The declaration names the legal entity that issued it and the date of issue.
- RoHS limits are stated by homogeneous material, with any exemption named.
- The REACH statement names the candidate list date and the basis of the calculation.
- Test reports name the laboratory, the method and the sample tested.
- Sub-supplier declarations are referenced, not summarised as a conclusion.
- A review date and a trigger list are recorded in the part file.
A certificate with no part number is a brochure
The most common failure in a declaration file is a document that is genuine but not tied to the part. Match the part number and revision before you match the logo.
Frequently asked questions
Does a RoHS declaration cover REACH as well?
No. RoHS restricts ten substances in electrical equipment by homogeneous material. REACH covers a much wider set of substances and, for articles, focuses on substances of very high concern at 0.1 per cent by weight of the article. A part can pass one and still need a statement under the other.
Is a test report better evidence than a declaration?
They do different jobs. A report is evidence about the sample that was tested, at the time it was tested. A declaration is the supplier's statement about the part in production. Use both, and check that the report names the same material and route as the part you are buying.
What is the 0.1 per cent threshold based on?
For REACH, it is 0.1 per cent by weight of the article as supplied. For RoHS, the limits apply to each homogeneous material. Confusing the two boundaries is one of the most common errors in supplier questionnaires.
How long is a declaration valid?
There is no single period. Review the declaration when the part, material, process, supplier or market changes, and when the relevant substance list is updated. Date every declaration you hold and record the next review date.
Sources and further reading
- European Commission, Directive 2011/65/EU on the restriction of hazardous substances, and Delegated Directive (EU) 2015/863
- European Chemicals Agency, REACH candidate list and guidance on requirements for substances in articles
- IEC 62474, Material declaration for products of and for the electrotechnical industry
Qumek Quality Desk
Quality team
The quality team responsible for first article inspection, PPAP packs, supplier audits and the records shipped with production parts.
Building a declaration file for a new part?
Send the bill of materials and the current drawing. The quality desk will mark the lines that have no evidence behind them.
Send the bill of materials