RoHS declaration of conformity: what it is and what it must state
What a RoHS declaration of conformity is, the ten substances restricted by EU Directive 2011/65/EU and their limits, and exactly what the declaration must state to support CE marking.
A RoHS declaration of conformity is the document in which a manufacturer certifies that an electrical or electronic product, and its parts and materials, stays within the maximum concentrations of restricted hazardous substances set by the EU RoHS Directive (2011/65/EU, as amended, commonly “RoHS 3”). For products in scope, RoHS conformity is one of the requirements behind the CE mark, so the RoHS declaration is closely tied to the EU Declaration of Conformity.
What RoHS restricts
RoHS limits ten substances by weight in any homogeneous material, meaning the limit applies at the level of each individually separable material, not the product as a whole. The maximum concentration values are:
| Restricted substance | Maximum concentration |
|---|---|
| Lead (Pb) | 0.1% |
| Mercury (Hg) | 0.1% |
| Cadmium (Cd) | 0.01% |
| Hexavalent chromium (Cr VI) | 0.1% |
| Polybrominated biphenyls (PBB) | 0.1% |
| Polybrominated diphenyl ethers (PBDE) | 0.1% |
| Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% |
| Butyl benzyl phthalate (BBP) | 0.1% |
| Dibutyl phthalate (DBP) | 0.1% |
| Diisobutyl phthalate (DIBP) | 0.1% |
The limit is per homogeneous material. A compliant assembly can still fail RoHS if a single solder joint, coating, or plastic within it exceeds a limit, which is why declarations rest on supplier data down the bill of materials.
What a RoHS declaration should include
A RoHS declaration is short, but it has to be specific about what it covers and what it relies on:
- The manufacturer and the product, model or part number(s) covered
- A reference to Directive 2011/65/EU (and amending Directive (EU) 2015/863 that added the four phthalates)
- A clear statement that the product conforms to the restricted-substance limits
- Any applicable exemptions being relied on (Annex III/IV), with the exemption cited
- The harmonised standard used to demonstrate conformity, typically EN IEC 63000
- An authorized signatory, place and date
How RoHS fits with CE and REACH
RoHS is one of the directives that can require CE marking. Where it applies, a manufacturer demonstrates conformity (usually via EN IEC 63000 technical documentation), draws up the declaration, and affixes the CE mark, the same chain described for the Declaration of Conformity. RoHS is often confused with REACH: RoHS restricts ten specific substances in electronics, while REACH is broader. Our RoHS vs REACH comparison explains where each applies, and the REACH & SVHC guide covers the substance-communication duties.
Because a RoHS declaration is a controlled document that must be re-issued when standards, exemptions, or the product change, it benefits from a fixed, version-controlled template rather than a copied file. DataSheets Pro provides a structured starting point; confirming scope, exemptions, the correct standard and current substance limits remains your responsibility as the manufacturer.
Start from the templateRoHS Declaration template: free & editable
Identify the product, reference the restricted substances and declare its status against RoHS, then export a supplier-ready PDF, free to start.
Open the template →Standardize this in DataSheets Pro
Turn what you just read into a repeatable, on-brand template, with no design tools required.