Machinery containing electrical or electronic components requires RoHS compliance (EU Directive 2011/65/EU restricts 10 hazardous substances in EEE: Lead, Mercury, Cadmium, Hexavalent Chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP). Compliance entails: Technical Documentation + EU Declaration of Conformity + CE Marking (not a “certification certificate”). Purely mechanical equipment (without electrical components) is exempt; specific exemptions are listed in Annex III/IV (e.g., lead in solder).
I.
RoHS Scope of Application
RoHS applies to Electrical and Electronic Equipment (EEE) that relies on electric currents or electromagnetic fields—machinery containing electronic control systems, motors, or sensors falls under the EEE category (e.g., CNC machine tools, packaging lines, pump station control cabinets). Purely mechanical equipment (manual machines or those without electrical parts) is excluded. For powered equipment exported to the EU, the standard combination is RoHS + EMC + LVD + CE—first, determine whether your machine contains electrical components.
II.
Restricted Substances and Limits
10 substances: Lead (1000 ppm), Mercury (1000 ppm), Cadmium (100 ppm), Hexavalent Chromium (1000 ppm), PBB/PBDE (1000 ppm each), and DEHP/BBP/DBP/DIBP (1000 ppm each). Exemptions: Lead in solder (e.g., Annex III 7(a)), lead and cadmium in ceramics/glass (new adjustments for 2025). Standard compliance involves using lead-free materials for electrical components, solder, and cables, supported by RoHS reports from suppliers.
III. Compliance Pathway
1. Technical documentation (BOM + test reports); 2. EU Declaration of Conformity (DoC); 3. CE marking (including RoHS declaration); 4. Testing (XRF screening + chemical verification); 5. Supply chain management (RoHS data from component suppliers)—Note: There is no official RoHS “certificate”; compliance relies on declarations and test documentation (exemption assessments transfer to ECHA starting August 2027).
IV.
Costs and Timeline
RoHS testing: Screening for a complete unit costs approx. 2,000–8,000 RMB per model (depending on the number of components); Timeline: 1–2 weeks (XRF rapid screening); Exemption application: Must be submitted to ECHA (long timeline, high cost); Component database: Zero cost for components where suppliers already hold RoHS reports—RoHS is a low-cost compliance item (often bundled with CE/EMC testing).
V.
Key Points for Overseas Buyer Verification
1. RoHS declaration (DoC includes RoHS); 2. Test reports (XRF/chemical); 3. Exemption list (explanation of exemptions, e.g., lead in solder); 4. Component compliance (supply chain RoHS data); 5. Bundled certifications (CE/EMC/LVD included)—Machinery containing electrical components requires RoHS compliance (limits on 10 substances; compliance relies on declarations and tests rather than a certificate); purely mechanical equipment is exempt; exemptions follow Annex III/IV;
buyers require the DoC and reports before signing the order.
