I. Basic Definitions
What to look for regarding basic definitions: According to EU regulatory practice, definitions are understood as follows: CE—The CE mark indicates that a manufacturer declares their product complies with applicable EU harmonized legislation (conformity assessment is the process of proving a product meets directive requirements, while market surveillance involves public authorities ensuring EEE compliance);
RoHS—The latest Restriction of Hazardous Substances Directive (2011/65/EU) came into effect on July 21, 2011 (aiming to prevent risks to human health and the environment associated with EEE by restricting specific hazardous substances—such as heavy metals, flame retardants, and plasticizers—for which safer alternatives exist, and by promoting EEE recyclability); CE (Broad Scope)—CE certification is a certification system and a shorthand for mandatory certification across Europe for various product types (primarily regulating EMC, safety, and other metrics; applicable to a wide range of categories including machinery, medical equipment, toys, and construction products); RoHS (Narrow Scope)—RoHS certification is an EU directive (CE certification covers a broader scope, whereas RoHS is just one specific directive within that framework, focusing on controlling toxic and hazardous substances in electronic products); Complementary Context—Mentioning RoHS inevitably brings up REACH (Europe’s regulation on toxic chemical substances)—Four key perspectives: the CE mark signifies compliance; RoHS restricts hazardous substances; the CE system is broad in scope; and the RoHS directive is narrow in scope. These four perspectives provide a clear distinction.
II.
Relationship Progression
What to look for regarding the progression of the relationship.
Based on EU legislative practice, the relationship can be understood through five key aspects: **Upgrade**—Directive 2011/65/EU (RoHS 2) replaced Directive 2002/95/EC as of January 3, 2013 (expanding the scope and clarifying definitions); **CE Status**—RoHS 2 is now a CE marking directive (it was one of the first regulations incorporated into the New Legislative Framework [NLF], defining obligations for all supply chain operators regarding product marketing); **CE Includes RoHS**—RoHS 2 is a CE marking directive, and RoHS compliance is a requirement for CE marking (manufacturers of all electrical and electronic equipment must comply with RoHS 2 to affix the CE mark; the old “green RoHS checkmark” label is no longer required because the CE mark now encompasses RoHS compliance); **Declaration**—The CE mark signifies the manufacturer’s declaration that the product meets all applicable EU directives; regarding RoHS, it confirms the product does not contain hazardous substances exceeding legislative limits; **Effectiveness/Compliance**—Covered products require technical testing, accompanying documentation, a Declaration of Conformity, and the CE mark (see Annex VI of the Directive for the declaration format; CE marking for RoHS products became effective January 2, 2013); **Conformity**—Once procedures demonstrate that EEE meets requirements, the manufacturer drafts an EU Declaration of Conformity and affixes the CE mark; in the absence of evidence to the contrary, EEE bearing the CE mark is presumed to comply with the Directive. These five aspects—RoHS 2 replacing the old version, its status as a CE marking directive, the inclusion of RoHS within CE marking, the declaration covering all directives, and the presumption of compliance—form a clear, progressive progression of understanding.
III.
Restricted Substances
What to consider regarding restricted substances.
Regarding RoHS directive practice, the substances are viewed in five ways: **Six substances**—restrictions apply to six hazardous substances (Lead [Pb], Cadmium [Cd], Mercury [Hg], Hexavalent Chromium [Cr6+], Polybrominated Biphenyls [PBBs], and Polybrominated Diphenyl Ethers [PBDEs]) in electrical and electronic equipment sold in Europe (with future restrictions planned for additional substances; “Made-in-China RoHS” guidelines); **Ten substances**—the RoHS directive currently restricts ten substances (including Pb, Cd, Hg, etc.; European Commission DG Environment); **Annex II**—once a substance is listed in RoHS Annex II, its concentration in EEE placed on the market must not exceed the maximum limit (European Commission “A Common Understanding”); **Substitution**—restricted substances are those that can be replaced by safer alternatives (promoting recyclability, as components can be recycled); **China**—China’s administrative measures apply to “electronic information products” (whereas the EU RoHS directive applies to electrical and electronic equipment with AC voltage not exceeding 1000V and DC voltage not exceeding 1500V; EU RoHS requires transposition into the national laws of member states for implementation, while China’s administrative measures are implemented directly without transposition into lower-level legal instruments; SGS); **Standards**—EU standards EN50581 and EN62321 (China standards SJ/T 11364-2014 and GB/T 26572-2011; China Electronics Standardization Institute)—the five perspectives on substances: starting with six, currently ten, Annex II limits, safer alternatives, and corresponding Chinese measures;
all five perspectives clarify the limits.
IV. Scope of Application
What defines the scope of application?
Regarding the scope of the RoHS Directive, consider these five aspects: EEE—RoHS legislation applies to all Electrical and Electronic Equipment (equipment requiring electric currents or electromagnetic fields to fulfill at least one intended function, or equipment for the generation, transfer, and measurement of such currents or fields, with voltage ratings not exceeding 1,000 V AC or 1,500 V DC); Categories—EEE coverage categories (1. Large household appliances, 2. Small household appliances, 3. IT and telecommunications equipment, 4. Consumer equipment, 5. Lighting equipment, 6. Electrical and electronic tools, 7. Toys, leisure, and sports equipment, 8. Medical devices, 9. Monitoring and control instruments—including industrial monitoring and control instruments, 10. Automatic dispensers, 11. Other EEE; see Annex I of Directive 2011/65/EU); Industry—Category 9 (monitoring and control instruments) includes industrial monitoring and control instruments (automation components, sensors, controllers, and instrumentation fall into this category); Comparison—CE marking applies to a broad range of categories (machinery, medical devices, toys, construction products), whereas RoHS is limited to EEE and its components; Restrictions—RoHS restricts the use of six hazardous substances in EEE; Marking—The RoHS Directive also establishes labeling requirements (manufacturer information, and the WEEE symbol indicating that the product must be collected and processed in accordance with WEEE regulations). These five points—EEE definition, the 11 product categories, Category 9 industrial monitoring, the broad scope of CE versus the narrow scope of RoHS, and WEEE labeling—clearly define the boundaries.
V.
Documentation and Testing
What to look for regarding documentation and testing.
Regarding documentation practices, consider these five aspects: CE—compliance requires a Declaration of Conformity, technical documentation, and safety/EMC test reports (Global Trade Plaza); RoHS—compliance requires a Declaration of Conformity and material declarations (derived from the supply chain/Global Trade Plaza); Testing—CE testing focuses on safety and EMC (Electromagnetic Compatibility), while RoHS testing focuses on chemical analysis of materials (Global Trade Plaza); Systems—the CE mark may only be affixed after testing and the completion of conformity assessment procedures mandated by applicable EU harmonized legislation (certificates themselves must not bear the CE mark; European Commission); Procedures—manufacturers must compile the necessary technical documentation and implement internal control procedures (once procedures demonstrate that EEE meets requirements, the manufacturer drafts the EU Declaration of Conformity and affixes the CE mark, subject to additional record-keeping and identification obligations; EUR-Lex); Compatibility—products for the GB market may bear the CE or UKCA mark (provided they meet GB RoHS regulations, including any exemptions), while products for NI and EEA markets must bear the CE mark (meeting EEA RoHS requirements); dual CE and UKCA marking is permitted (GOV.UK RoHS regulations).
Summary of the five document categories: DoC/technical documentation, material declarations, safety/EMC test reports, post-testing CE marking, and GB dual marking—ensure all five are in order.
Conclusion
The distinction between CE and RoHS requirements for automation components can be defined across five dimensions: definition, relationship, substances, scope, and documentation.
Definitions—The CE mark indicates a manufacturer’s declaration that a product meets applicable EU harmonized legislation requirements (covering certification systems, EMC and safety controls, and broad categories such as machinery, medical devices, toys, and construction products); RoHS is an environmental directive under the CE framework (Directive 2011/65/EU, restricting hazardous substances in Electrical and Electronic Equipment—EEE). Relationships—RoHS 2 replaced Directive 2002/95/EC as of January 3, 2013; RoHS 2 is a CE-related directive; RoHS compliance is a requirement for the CE mark; the CE mark now encompasses RoHS compliance; the Declaration of Conformity format is specified in Annex VI of the directive; compliance is presumed unless evidence to the contrary exists. Substances—Started with six (lead, cadmium, mercury, hexavalent chromium, PBB, PBDE) and now covers ten; limits are defined in Annex II; alternative substances exist; corresponding Chinese regulations for electronic information products include SJ/T 11364-2014 and GB/T 26572-2011. Scope—EEE requires electric currents or electromagnetic fields; voltage ratings below 1000V AC or 1500V DC; covers 11 product categories (including Category 9: industrial monitoring and control instruments, which encompasses automation components); CE has a broader scope than RoHS; WEEE labeling applies. Documentation—CE requires a Declaration of Conformity (DoC), technical documentation, and safety/EMC test reports; RoHS requires a declaration of compliance and material declarations; CE testing focuses on safety and EMC, while RoHS testing focuses on material chemistry;
GB markets accept CE or UKCA; the EEA requires CE; dual marking is permitted. Industry Summary—In short: CE covers safety and EMC, while RoHS covers hazardous substances;
RoHS is a directive under the CE framework, and the CE mark incorporates RoHS compliance—display both marks for worry-free exporting.
