RoHS testing: build an evidence plan around materials
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Test the material that carries the substance risk.

An electrical product can contain many materials: plastic housings, cable insulation, solder, coatings and metal parts. RoHS testing starts by identifying the product and the materials that need assessment. TTS helps turn the product information and available supplier evidence into an agreed testing brief. This is useful for a new design, a change of material supplier or a buyer requesting evidence for selected components. The scope should identify the samples and materials covered so that a result is not assumed to represent every part of a finished product.

What to check in the evidence

01

Homogeneous-material coverage

Break the product into relevant plastics, metals, solder, coatings, cable insulation and other distinct materials. Link each submitted sample to that map.

Why it matters

A whole-product description does not show which material was analysed; dilution or unclear sample grouping can make the result difficult to interpret.

02

Screening versus determination

Agree how X-ray fluorescence (XRF) screening and substance-specific analytical methods will be used.

Why it matters

Elemental screening is not the same as identifying every restricted compound. For example, total bromine alone does not identify PBB or PBDE.

03

Substances and exemptions

Clarify the applicable RoHS scope, restricted-substance set and any claimed exemption for the component and application.

Why it matters

An exemption needs an applicable basis and supporting information; it is not a general approval for the entire product.

04

Evidence and changes

Record the material supplier, component revision, sample identity and supporting declarations or analytical reports.

Why it matters

A new resin, pigment, coating or solder source can change the evidence needed, even when the finished model number stays the same.

An illustrative scenario

A new cable supplier, an unchanged product model.

Illustrative example: a supplier changes the cable insulation but retains the model number and an older RoHS report. Identify the changed material, compare the report’s sample description and obtain evidence for the new supply. A report on the previous cable should not be presented as testing of the replacement simply because both cables look black.

Prepare these before the next step

  • Product model, intended use and destination market.
  • Bill of materials or clear component and material photographs.
  • Available supplier declarations, previous reports and the requested coverage.

Use the results to investigate a material issue, request supplier clarification or strengthen the evidence file for the tested product. A report covers the identified samples and scope; changes to materials or components may require further review.

Sources & further reading

  • RoHS Directive 2011/65/EU & (EU) 2015/863 ↗

    The EU framework for restricted substances in covered electrical and electronic equipment. Product scope and exemptions are reviewed before testing.

  • IEC 62321 series ↗

    Analytical methods for substances in electrotechnical products. The selected part and method must match the material and substance question.

  • IEC 63000 ↗

    Technical-documentation framework for restricted-substance assessment; a report is linked to the broader manufacturer evidence file.

Confirm product-specific scope and the applicable edition with TTS before making a compliance decision.

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