When an EU or UK buyer asks for RoHS evidence, the request usually arrives as a material declaration, a laboratory report, or a quotation for "RoHS testing services". RoHS restricts the use of certain hazardous substances in electrical and electronic equipment placed on the EU market, and UK RoHS mirrors the same substance limits. Your buyer, marketplace or customs agent may ask you to show that the materials in your product meet those limits. That evidence is produced by testing, not by visual inspection alone.
This guide explains what the ten limits are, how testing is structured around homogeneous materials, what a useful testing service should deliver, and which common mistakes waste the test fee. It is written for importers, wholesalers, brand owners and e-commerce sellers buying consumer goods from China.
The ten restricted substances
RoHS restricts ten substances. The limits below are the directive's maximum concentration values by weight in homogeneous materials. A homogeneous material is a material of uniform composition that cannot be mechanically separated into different materials; examples include a plastic housing, wire insulation, solder, a coating, or a brass pin.
| Restricted substance | Limit by weight in homogeneous materials |
|---|---|
| Lead | 0.1% |
| Mercury | 0.1% |
| Cadmium | 0.01% |
| Hexavalent chromium | 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% |
How RoHS testing works
RoHS testing is organised around homogeneous materials, not around a finished product as a single unit. A product can contain dozens of materials: ABS housing, PVC cable jacket, copper wire, tin solder, nickel plating, printed circuit board laminate, ink, adhesive and others. Each relevant material is tested or covered by a material declaration, because the limit applies at the material level. A multi-material product can therefore need several material tests, even when it is sold as one item.
Screening and full chemical analysis answer different questions. XRF screening is quick and non-destructive. It can flag the presence of elemental lead, mercury, cadmium, chromium and bromine in a material, which helps prioritise where to test. XRF is not a complete RoHS test: it does not identify PBB, PBDE or the four phthalates, and readings can be affected by coatings, alloys, surface contamination or material thickness. When the buyer needs defensible evidence, the laboratory confirms results with full chemical analysis.
The output is a laboratory report issued by the accredited laboratory, carrying that laboratory's report number. We are not a testing laboratory, and we do not issue certificates or test reports in our own name. Our role is to coordinate the laboratory scope, prepare the documents, and help you read the result against the product and market requirement.
What a testing service should deliver
A useful RoHS testing service should do more than send a price. It should translate your bill of materials and product construction into a test plan. At minimum, expect the following:
- A test plan matched to the product's materials. The plan should identify which homogeneous materials need testing, which can be covered by existing reports or declarations, and where screening is enough to decide the next step.
- Sampling of the actual production version. The laboratory sample should come from the production version you intend to ship, not a prototype or a purchased competitor sample. If a material or supplier changes, the test plan should be reviewed.
- The laboratory report. You should receive the report issued by the laboratory, with its report number, test method, sample identification and results. This is the document your buyer or market surveillance authority can trace.
- Help aligning labels and the DoC. RoHS evidence often sits beside CE marking documents. We can help prepare the document set and align the declaration of conformity with the tested product version and the destination market.
For the wider document trail around CE marking, see our CE compliance testing guide.
This is handled under our compliance testing coordination service. We coordinate accredited (ISO 17025) laboratories and buyer-designated third-party inspection agencies. If you designate an agency such as SGS, Bureau Veritas, TÜV or Intertek, we coordinate that scope; we do not claim partnership, accreditation or affiliation with those agencies. We are a coordination service: in-process and pre-shipment checks are performed by the executing inspection party as part of a sourcing order, and we coordinate laboratory testing and document preparation where your order requires it. Testing and documents are arranged per product, per destination market, per batch. Lab fees are paid by you directly to the laboratory; our coordination and document-preparation service fee is CNY 500-2,000 per order. Typical laboratory reports take 15-45 days, depending on the test scope and laboratory schedule. Legal responsibility for compliance rests with the manufacturer or importer. We coordinate and match requirements, and can introduce an EU authorised representative.
Mistakes that waste the test fee
Testing a golden sample instead of production units
A golden sample is useful for appearance and function, but it is not evidence for the batch. If the report is based on a hand-made prototype, a purchased reference sample, or a sample from a different production line, the report may not represent the goods you ship. Take samples from the actual production version, record the sample identification, and keep the link between the sample, the material batch and the report.
Reusing a report after a material or supplier change
A RoHS report is linked to the tested material and version. If a plastic resin, solder alloy, cable jacket, coating, ink or supplier changes, the material composition can change with it. Reusing an old report without review creates a documentation gap. Review the bill of materials when a change is proposed, and re-test or obtain a new declaration where the change affects a material in scope.
Testing the finished product once instead of its materials
A single finished-product test can miss the material-level question. RoHS limits apply to homogeneous materials, so the test plan should cover the relevant materials rather than relying on one composite result. For an electronics order, pair material evidence with electronics inspection services so pre-shipment checks and compliance evidence are reviewed together.
Leaving testing until after shipment
If testing starts after the goods are packed or shipped, your options narrow. A failed material can trigger quarantine, rework, replacement or a supplier change, and those actions are harder once the order is in transit. Build the test plan and document requirements into the order terms when the order is placed, and schedule final OQC before shipment so the report can be reviewed while correction is still practical.
RoHS evidence works better when it is planned around materials, sampled from production, and reviewed before shipment. If you are preparing an order from China and need the laboratory scope, document set and inspection checkpoints aligned, contact [email protected]. Certificates available upon request.