RoHS Has No Certification Body
I sometimes get asked, “Do you have RoHS certification?”
Every time, I answer, “There’s no such thing as RoHS certification.”
Most of the time, the air fills with a mix of distrust and unease.
I’ve fortunately shipped several products bearing the CE mark. I’ve put together the technical documentation and signed the declaration of conformity myself. So I think I understand the scheme itself. Even so, this conversation stalls at exactly the same point every time.
The other person isn’t wrong, though. The word “certification” circulates normally within the industry. Sales people say it, customers say it, sometimes even the people doing the design say “RoHS certification.” Come to think of it, it’s quite a state of affairs that the name of something that doesn’t exist rides this smoothly through conversation.
The substance of the scheme itself is dry.
The manufacturer judges conformity itself and declares it itself. There’s no filing. There’s no registration. There’s no third-party review. All that’s required is technical documentation, an EU declaration of conformity, and affixing the CE mark. The declaration of conformity itself is a single A4 page. Identify the product, state the directives and standards it complies with, and sign it. That satisfies the entire legal requirement.
The technical documentation is assembled in line with the harmonized standard EN IEC 63000. Its content is risk-based, structured around collecting evidence from any of the following: supplier non-use declarations, material composition data, or analysis results. The design philosophy behind the analysis is “only test where something looks suspicious.”
This is rational. RoHS thresholds apply per homogeneous material, so if you seriously analyzed every single material in one piece of electronic equipment, you’d end up with hundreds of items to test. Nobody does that. If you did, you’d never ship the product.
So the cost is far lower than people imagine. Certification cost is zero. What actually takes work is sending out and collecting supplier questionnaires, then analyzing a handful of risk points and putting together the paperwork. The risk points themselves are concentrated in predictable places. Modern electronic components are almost all already compliant, so what actually trips things up tends to cluster around lead in free-machining brass, chromium in chromate treatments, and phthalate esters in PVC cable sheathing. I’m always careful with generic cables.
Incidentally, that lead in brass hangs on exemption 6(c).
This exemption has been extended for nearly twenty years running. Most recently it was renewed in November 2025, pushing the deadline to the end of June 2027. And against that new deadline, the next extension request has already been filed. Under the rule that the exemption remains valid until the Committee makes a decision, the deadline effectively never arrives as long as someone keeps filing.
(At this point, I can’t tell anymore which one is actually the main rule.)
So much for the scheme itself.
Now for how it actually plays out in practice: customers ask for a test report.
Legally, it isn’t required. A declaration of conformity is sufficient. And yet they ask for it anyway. As a matter of business custom, this is, if anything, the mainstream expectation.
So do I provide it? Honestly, I weigh it.
Often I’m the third quote in a competitive bid, or a subcontractor several layers down on a tender I’m not even sure will be won. In those cases, I push back. Or rather, pushing back is what happens more often than not.
If it looks like it makes business sense, I provide it. I send a few of the main materials to an ISO/IEC 17025-accredited lab and get an analysis report. It runs somewhere between one hundred thousand and three hundred thousand yen, so for a deal that’s genuinely worth pursuing, it’s well worth the cost.
In other words, I’m not deciding whether to submit the paperwork based on regulation.
I’m deciding based on how serious the deal is.
And presumably the customer isn’t asking because they actually want to verify anything either. They ask, and watch whether we come through with it. If we do, they know we’re serious. If we push back, well, that’s about how serious the deal was in the first place.
A document with zero legal meaning is functioning, for both sides, as a gauge of seriousness.
The scheme chose not to install a verifier. It decided nobody would check. What the market put into that empty seat wasn’t a verifier. It was litmus paper with a price tag on it.
That uneasy atmosphere, then, is the correct response. Not trusting a scheme that nobody verifies is rational as a judgment, not an emotion. The scheme only ever said “trust me,” so answering “I don’t” is entirely consistent.
Still, having written all this, I notice something.
The technical documentation is still, in fact, talking about lead.
Past the declaration, nobody is talking about lead anymore.
I recall going pale over Chinese radio certification more than ten years ago. They demanded every drawing and every piece of software, and I thought, doesn’t that mean someone could just build a copy? I thought that was excessive, and I still think it was excessive.
But at least, in that case, someone was actually looking.
With RoHS, nobody is looking.
Asked which one feels safer, I find myself, honestly, a little stuck.
This piece was drafted and directed by Kuzuryu, written by AI.
Originally published in Japanese at https://clazytech.com/2026/07/1703/. Translated with LLM assistance and reviewed before publication.