RoHS for electronic merch items

What it requires

• Restrict 10 substances (lead, mercury, cadmium, hex chrome, PBB, PBDE, DEHP, BBP, DBP, DIBP)
• CE-mark every electrical merch item with RoHS Declaration of Conformity
• Maintain technical file for 10 years post last placement
• Identify importer and place name + address on the article (EU 2019/1020)
• Conduct EN IEC 63000 documentation review
• Run XRF or ICP-OES tests per harmonised standard
• Keep supplier RoHS declarations as part of conformity evidence

How it impacts merch programs

• Power banks must show CE + RoHS DoC + battery transport class
• USB cables: solder joints traditional source of lead exceedance
• Plastic housings with phthalate plasticisers fail DEHP / DBP limits
• PCB-mounted components must use lead-free solder (RoHS-compliant alloys)
• LED lanyards / lit-up merch must include RoHS + REACH declarations
• Repair-by-design guidance now relevant for ESPR follow-on rules

Documentation packet — what suppliers must provide

1. EN IEC 63000 technical documentation file
2. EU Declaration of Conformity (signed)
3. ISO 17025 test report (XRF screen + ICP-OES confirmation)
4. Bill of materials with substance content per homogeneous material
5. Supplier RoHS declarations for sub-components
6. CE-mark artwork file + placement specification
7. Importer details + EU Authorised Representative if applicable
8. Risk assessment per EN IEC 63000 Annex

Decision tree — when does this framework apply?

• Is the item an EEE (electrical or electronic equipment)? RoHS applies
• Is it placed on the EU market? DoC + CE-mark required
• Is it Category 11 (catch-all) or specific? Affects exemptions
• Are exemptions claimed (e.g., lead in glass)? List them in the DoC

Penalties for non-compliance

• Per-Member-State fines (UK GBP 5 000 per breach; Germany EUR 100 000+)
• Customs seizure of non-compliant shipments
• Withdrawal-from-market order from national authority
• Reputational + e-commerce platform delisting (Amazon EU, etc.)

How we help

• RoHS-compliant catalogue baseline: every electronic SKU pre-tested
• EN IEC 63000 technical file maintained per SKU for 10 years
• CE-mark artwork integrated into branding files
• Battery + transport classification (UN 38.3) bundled with electronics
• Annual RoHS retest cycle with cost included in unit price
• Importer-of-record support if you lack an EU entity

Related frameworks

• Reach Svhc Merch
• Cpsia Toy Safety
• Cbam Carbon Border

Related resources

• Glossary of compliance terms
• Material catalogue
• Sustainability report 2026
• Data Processing Addendum
• Whitepapers and reports

Frequently asked questions

Does RoHS apply to a power bank giveaway?

Yes: power banks are EEE Category 11 and require CE-mark + DoC + RoHS compliance.

What about a cable that ships with the power bank?

The cable is an EEE component and must meet RoHS independently or as part of the assembly.

Can we self-declare RoHS?

Yes: the EU Declaration of Conformity is the manufacturers self-declaration; technical file must support it.

How often do we need to retest?

When the design or supplier changes, or per your periodic-testing plan; we run an annual baseline test cycle.

Whats the difference between RoHS 2 and RoHS 3?

RoHS 3 (EU 2015/863) added 4 phthalates (DEHP, BBP, DBP, DIBP): fully in force since 22 July 2019.