RoHS Certificate: The Manufacturing Industry's "Identity Card" for Environmental Compliance
In manufacturing trade negotiations and product access, "RoHS certificates" frequently appear, and many buyers and partners consider them a prerequisite for cooperation. But for those new to environmental compliance, what exactly is RoHS? Why do all kinds of products require this certificate? What standards and requirements are behind it? Today, Kailai Machinery will address these questions one by one regarding the RoHS certificate.
What is RoHS? From Origin to Core Definition
![]()
RoHS is not just a single "certificate name"; it is essentially a global environmental regulation. Its full name is the "Restriction of Hazardous Substances Directive," officially enacted by the European Union in 2003. Its original core goal was to reduce the environmental and human health risks of electrical and electronic products by restricting the use of hazardous substances.
1. List of Core Controlled Substances
The scope of RoHS control has continued to expand with evolving environmental requirements. Initially, only six categories of substances were regulated, but this has now been expanded to 10 key hazardous substances, including:
The traditional six categories: lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr⁶⁺), polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers (PBDEs);
![]()
Four new categories: dibutyl phthalate (DBP), butyl benzyl phthalate (BBP), di(2-ethylhexyl) phthalate (DEHP), and diisobutyl phthalate (DIBP).
![]()
These substances are either toxic or difficult to degrade. If they remain in the environment for a long time or come into contact with the human body through products, they can cause health risks such as neurological damage and organ disease, and may also cause soil and water pollution.
2. Scope of Control: Beyond Electrical and Electronic Products
Many people mistakenly believe that RoHS only applies to complete electronic devices such as mobile phones and computers. In fact, its scope of control has been extended to "electrical and electronic equipment, their components, and raw materials." From small components like resistors and connectors on circuit boards to large metal casings for home appliances, motor components for industrial equipment, and even plastics and coatings used in product packaging—all components or production aids of electrical and electronic equipment must comply with RoHS standards. Currently, some non-electronic sectors (such as medical devices and automotive parts) are also actively integrating into RoHS compliance management due to environmental protection requirements.
Why is a RoHS certificate necessary? Three Core Values
A RoHS certificate is more than just a "formal document"; it is a key credential for companies to enter the market, earn trust, and fulfill their responsibilities. Its necessity is reflected in three core aspects:
1. A "hard threshold" for market access
The EU is the birthplace of the RoHS Directive and the first region to implement strict controls. Any electrical and electronic product wishing to enter the EU market must pass RoHS testing and possess a certificate. Failure to do so will result in customs detention, market recalls, and significant fines.
With the globalization of environmental awareness, nearly 30 countries and regions, including China, the United States, Japan, and South Korea, have introduced localized RoHS regulations. China's "National RoHS" covers the entire electronic information product industry chain; California's Waste Electronics Recycling Act explicitly requires products to comply with RoHS limits; and Japan's Law on the Control and Management of Emissions of Certain Chemical Substances includes RoHS-controlled substances under its regulations. For companies, RoHS certification has become an essential key to unlocking mainstream global markets.
2. The "Foundation of Trust" in Supply Chain Cooperation
In the modern manufacturing supply chain, environmental compliance has become a core criterion for upstream and downstream collaboration. Brands (such as Apple, Huawei, and Samsung) prioritize RoHS compliance when selecting suppliers. Exceeding hazardous substance standards in upstream components can directly lead to non-compliance in downstream finished products, leading to chain reactions such as damaged brand reputation and product returns in the end market. Therefore, companies holding RoHS certificates can gain the upper hand in supply chain competition and are more likely to secure long-term partnerships from brands.
3. A "Visual Reflection" of Corporate Responsibility and Brand Value
RoHS compliance, at its core, represents a company's commitment to the environment and consumer health. Obtaining a RoHS certificate requires companies to establish a comprehensive process control system, from raw material procurement to finished product shipment. These measures include eliminating harmful processes such as lead-based solder and chromium-free passivation, selecting environmentally friendly raw materials, and optimizing pollutant emissions during production. These measures not only reduce environmental damage during the production process but also protect consumers from exposure to harmful substances through product use, demonstrating a company's commitment to social responsibility.
Today, consumers are increasingly environmentally conscious and are more willing to choose products certified by environmental standards such as RoHS. Companies holding RoHS certificates can enhance their brand's environmental image, strengthen consumer trust, and establish differentiated market competitiveness.
RoHS Testing and Compliance: From Process to Key Points
Obtaining a RoHS certificate isn't a one-time test. Companies must establish a systematic compliance management system, focusing on two key areas: testing processes and full-chain control.
1. RoHS Testing: Authoritative Institutions and Key Processes
RoHS testing must be performed by a third-party, authoritative institution with CMA, CNAS, or other qualifications. The process is broadly divided into four steps:
Sample Submission: Companies must provide samples of "all homogeneous materials" of their products, meaning single materials that cannot be mechanically separated (such as plastic casings, metal pins, solder joints, coatings, etc.), ensuring that every component of the product is covered.
Preliminary Screening: Testing agencies use X-ray Fluorescence Spectrometry (XRF) to rapidly screen samples for hazardous substances. This method requires no sample destruction and offers high efficiency.
Precision Testing: For samples suspected of exceeding standards in the preliminary screening, inductively coupled plasma mass spectrometry (ICP-MS) and gas chromatography-mass spectrometry (GC-MS) are used. Quantitative analysis using precise methods such as GC-MS is used to determine the specific content.
Certificate issuance: If the hazardous substance content of all homogeneous materials is below the limit (e.g., lead and hexavalent chromium do not exceed 0.1%, and cadmium does not exceed 0.01%), the agency will issue a RoHS test report and compliance certificate.
It is important to note that the validity period of a RoHS certificate is strictly tied to the product's "raw materials, process, and supplier"—if any of these changes occur (e.g., changing the plastic pellet supplier or adjusting the electroplating process reagents), the original certificate automatically becomes invalid and requires retesting.
2. Full-chain compliance: Eliminating risks at the source
The core of RoHS compliance is "prevention," not "after-the-fact remediation." Companies must establish "three lines of defense":
Raw material control: Request RoHS test reports from suppliers, explicitly requiring them to provide a Material Declaration of Content (SDS) to prevent the purchase of materials containing substances exceeding the limit; regularly conduct sampling and retesting of key raw materials (e.g., solder and plastic pellets).
Production process control: Optimize production processes and replace harmful processes with environmentally friendly alternatives, such as replacing lead-based solder with lead-free solder and solvent-based paint with water-based paint. Establish "Environmentally Friendly Process Operating Specifications" in the workshop to prevent the introduction of hazardous substances during production.
Finished product inspection and control: Incorporate RoHS compliance into factory inspection standards, randomly sample each batch of products for inspection, and ensure that finished products meet standards before being released to the market.
Common Misconceptions: Debunking Misconceptions About RoHS
Myth 1: "Only complete electronic devices require RoHS certificates, not components?"
Truth: RoHS regulates "electronic and electrical equipment and their components." As components of a complete device, the compliance of the component directly determines the compliance of the complete device. If the component is non-compliant, the entire device is considered non-compliant. Therefore, component manufacturers also need to obtain RoHS certificates to enter the brand's supply chain.
Myth 2: "A RoHS certificate is valid for life, and a single test is enough to fix it once and for all?"
Truth: RoHS certificates are not "valid for life." A certificate is only valid for the specific batch, process, and raw materials used at the time of testing. If the raw materials, supplier, or process change, the original certificate will no longer cover the new batch and retesting is necessary.
Myth 3: "Doesn't a RoHS certificate apply to products sold domestically, only to exports?"
Truth: China's "National RoHS" regulations, which have been in effect for over a decade, explicitly require that electronic information products (such as mobile phones, computers, and televisions) entering the domestic market comply with hazardous substance restrictions and bear environmental labels. With tightening domestic environmental regulations, some e-commerce platforms (such as JD.com and Tmall) now require electronic products listed on their platforms to provide RoHS certificates, making RoHS compliance for domestically sold products inevitable.
Myth 4: "As long as the hazardous substance content 'doesn't exceed the standard,' it doesn't matter whether it exists or not."
Truth: RoHS regulates "intentionally added" and "content limits." Even if an impurity isn't intentionally added, it's still considered non-compliant if the content exceeds the limit. For example, even if cadmium is present in metal materials due to insufficient raw material purity, even at a concentration of only 0.015% (exceeding the 0.01% limit), it will not comply with RoHS standards. Therefore, companies must control the impurity content of raw materials at the source, rather than focusing solely on "intentionally added" substances.
As an experienced custom metal parts manufacturer, Kailai Machinery has the capability to produce in full RoHS compliance throughout the entire process and environment. If you have any requirements, please contact us and we can provide you with a prompt quote.