Customers Want RoHS and REACH Reports, So Tell the Two Documents Apart

A customer in Southeast Asia is running incoming inspection and asks by email for one RoHS document and one REACH document.

You send the documents over and the reply comes back in one line: Are these two general declarations, or are they issued per grade?

The question is not polite, but it hits the point.

RoHS and REACH documents look much the same on the surface. Both are stamped PDFs, and either will clear a file check. But the way they are issued is different, and the testing behind them is completely different.

One states that the entire product range complies. The other states what was actually measured on the samples of that one grade from that one batch.

At incoming inspection, what the customer needs is the second one.

A general declaration is a commitment, not a test report

Start with what a general declaration looks like.

Its header reads Certificate of Compliance for ROHS, known in Chinese as the RoHS certificate of compliance. The body states which product ranges it covers, a table of limit values for the 10 restricted substances is attached, and it closes with a company stamp.

Those 10 limit values are the set fixed by the EU RoHS 2.0 directive (2015/863/EU). Apart from cadmium (Cd) at 0.01 %, the other 9 are all 0.1 %.

The paragraph that matters is not in the table. It is after the table.

The declaration states: based on our current level of knowledge and the data provided by our raw material suppliers, we provide this confirmation. Routine analysis of whether raw materials and/or products contain the substances listed above is not part of our quality control plan or product specification parameters.

That sentence makes the nature of a general declaration clear.

It rests on supplier data and the current level of knowledge, and it answers whether the product range complies with the regulation. What it does not answer is: what the batch you are holding actually measures.

So where a general declaration belongs is clear. When a customer wants a document showing that the company runs a RoHS compliance system, or wants a file covering a whole range, it serves its purpose.

But when the customer wants to check whether their own grade is good enough for their part, a general declaration cannot answer that.

For a report issued per grade, the number and the date are what matter

A report issued per grade is a different route.

The sample goes to a third-party testing laboratory, the laboratory runs the 10 substances by the IEC 62321 series of methods and issues a report carrying a unique number. The report states the grade submitted, the sample receipt date, the test date, the measured value and the detection limit for each substance, and ends with a conclusion.

Take our own third-party RoHS report as an example: report number A2240059620101001C, submitted grade halogen-free flame retardant PC/ABS HF-1210, sample receipt date 30 January 2024, report issue date 2 February 2024. The testing body is Shanghai Centre Testing International Pinbiao Co., Ltd.

The same grade has earlier versions behind it. Report number A2230043447101001C, issue date 15 February 2023. The English version, report number A2210363565101001, issue date 7 September 2021.

Three reports, three different numbers, three different dates. At incoming inspection the customer asks which batch this report covers, so the number and the date matter more than the file name.

There is one more line in the report that is easy to miss, but customers have asked about it.

The conclusion column reads N.D., meaning not detected, below the method detection limit. The detection limit is not one blanket figure. It is stated separately for each of the 10 substances: lead (Pb), cadmium (Cd) and mercury (Hg) at 2 mg/kg, hexavalent chromium (Cr(VI)) at 8 mg/kg, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs) at 5 mg/kg, and the phthalates (DEHP, BBP, DBP, DIBP) at 50 mg/kg.

The matching limit values are 1000 mg/kg for Pb, Hg, Cr(VI), PBBs, PBDEs and the phthalates, and 100 mg/kg for Cd.

If the customer pushes for measured values, this report can answer. The general declaration cannot.

REACH runs on a different list, and that list has a shelf life

REACH and RoHS are not the same thing. Do not read them as one.

RoHS governs 10 substances with fixed limit values. Test once, the conclusion stays valid. REACH governs the SVHC list, the list of substances of very high concern, and that list keeps growing.

Our REACH report for halogen-free flame retardant PC/ABS HF-1210 carries report number A2210363565102001C, issue date 11 September 2021. The test basis is regulation (EC) No 1907/2006, screening the sample for 219 substances of very high concern, with 1 candidate substance added that had on that day already been listed as an intention to become legislation.

All 219 substances plus that 1 candidate substance came out below 0.1 % (w/w).

That conclusion was complete at the time. The list will keep growing, so a REACH report must always be read with its issue date. A customer checking a three-year-old report against today's list will find gaps caused by the list changing, not by the material.

Which document the customer needs: three questions to settle it

When a customer asks, three questions in this order will settle it.

First, is this document covering the product range, or is it tied to one grade?

Look at the header. If it names several product ranges, carries a limit value table and is stamped with the company seal, it is a general declaration. If it states the submitted grade, the sample receipt date, the report number and the signature and stamp of the testing body, it is a grade-specific test report.

Second, give me the report number and the issue date.

Only a number lets you trace back to the submitted sample and to that batch of test records. The date determines which point in time the report stands for.

Third, is it RoHS or REACH, or do you need both?

RoHS covers the 10 substances with limit values, REACH covers the SVHC list. Among end customers exporting into the EU, more need both than need only one.

After the three questions, what the customer has in mind usually becomes one concrete action: quote the grade and send over the RoHS and REACH reports issued for that grade.

If you need a third-party report for a specific grade, send us the grade and the destination country, and we will confirm which document applies to the application and which set of test standards to use.

Reply with the grade name and we will send the complete grade catalogue.

Qingdao Yunsu Polymer Material Technology Co., Ltd.