Japanese manufacturers exporting electronic and electrical equipment to the European Union are required to demonstrate compliance with the RoHS Directive (2011/65/EU and its amendments). The testing requirements are more nuanced than a single XRF scan, and getting the documentation wrong can delay market entry.
Which substances does RoHS restrict? ¶
RoHS 2 restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates (DEHP, BBP, DBP, DIBP) added under the 2019 amendment. Each substance has a maximum concentration value (MCV) expressed as a weight percentage of homogeneous material. Lead, for example, is restricted to 0.1% by weight.
Why XRF alone is not sufficient for a full submission ¶
XRF screening is fast and non-destructive, which makes it a useful first step. However, XRF cannot distinguish hexavalent chromium from other chromium species, and it cannot reliably quantify phthalates. For a complete compliance documentation package, XRF screening should be followed by ICP-OES confirmation for flagged metals and GC-MS analysis for phthalates. Our RoHS Pre-Screening package is designed as the first stage of this process.
What documentation does the EU require? ¶
The EU requires a Declaration of Conformity (DoC) and a Technical File. The Technical File should include test reports from a competent laboratory, a description of the testing methodology, and evidence that the substances were tested in the relevant homogeneous materials. The test reports do not need to come from an accredited laboratory under RoHS, but the methodology must be documented and defensible.
Preparing your submission with Drift Core Lab ¶
Our Regulatory Compliance Testing service prepares the technical documentation package alongside the test report. This includes a test plan, a description of the homogeneous materials tested, and a summary table of results against the MCV thresholds. Clients have found this reduces back-and-forth with European certification bodies. The service starts from ¥88,000 per submission.
If you are preparing a first RoHS submission or updating documentation for a product revision, contact us at lab@driftcorelab.com. We can review your product category and recommend the appropriate test scope.