The customer's email is polite: "Please provide your RoHS report." The supplier replies with an ISO 9001 certificate. Three rounds later the customer has filed you under "not professional" — not because the product has a problem, but because the question was answered wrong.
On exports to the EU, three words come up most often: RoHS, REACH and halogen-free. They are routinely bundled into one phrase — "environmental requirements" — but they are three entirely different things: different legal basis, different object of assessment, different documents. This article draws the boundaries and gives the document list customers actually ask for during an audit.
| Item | Basis and nature | Assessed on | Deliverable |
|---|---|---|---|
| RoHS | Directive 2011/65/EU as amended by (EU) 2015/863; mandatory law, within CE scope | Homogeneous material | Test report plus Declaration of Conformity (DoC) |
| REACH | Regulation (EC) 1907/2006; mandatory law, independent of CE | Article | SVHC content statement plus SCIP notification |
| Halogen-free | IEC 61249-2-21, J-STD-709 and similar; customer specification, not law | Material / laminate | Halogen content test report |
The only thing the three share is that all of them have to be traced down to the material level. Neither appearance nor functional testing can prove any of them.
RoHS currently restricts ten substances: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and the four phthalates added in 2015 (DEHP, BBP, DBP, DIBP). Limits are 0.01% for cadmium and 0.1% for the rest.
The key point is that 0.1% is calculated on homogeneous material — a material that cannot be separated by mechanical means, such as a single solder joint, a plating layer, a plastic housing or a piece of lead frame. You cannot weigh the whole board and average it; the board has to be broken down to material level and verified item by item.
A report saying "the unit passes RoHS" tells you nothing. What matters is which material layer, which substances, and what limit.
Three places where this goes wrong:
The part of REACH most relevant to electronics manufacturing is the SVHC candidate list. Its logic differs fundamentally from RoHS: RoHS says "you may not exceed the limit", REACH says "you may exceed it, but you must say so".
The most useful phrasing for a customer is therefore not "we comply with REACH" but "based on the SVHC list of [month, year], no SVHC above 0.1% was found in the articles of this product" — or, better, the specific substances, locations and content. The first sentence cannot be held to account; the second is a usable declaration.
In the electronics industry, halogen-free (or low-halogen) usually means restricting chlorine and bromine, judged against IEC 61249-2-21 or the grade definitions in J-STD-709:
| Item | Limit | Notes |
|---|---|---|
| Chlorine (Cl) | ≤ 900 ppm | Main sources: chlorinated flame retardants, residues of some cleaning agents |
| Bromine (Br) | ≤ 900 ppm | Main source: brominated flame retardants, common in FR-4 laminate |
| Cl + Br combined | ≤ 1,500 ppm | Each may pass while the total fails — still a fail |
Test methods usually follow EN 14582 (oxygen bomb combustion with ion chromatography) or the IEC 61189 series for laminates. One misunderstanding appears constantly:
Halogen-free ≠ lead-free ≠ RoHS compliant. RoHS restricts only two specific brominated flame retardants, PBB and PBDE; it says nothing about chlorine or about other brominated compounds. A perfectly valid RoHS report can sit alongside a laminate with ten times the bromine limit.
The reverse also holds: a halogen-free laminate is usually lead-free, but that does not make the solder, plating and auxiliary materials halogen-free across the whole process. If you are submitting a halogen-free report, state clearly whether it covers the laminate or the assembled board including auxiliaries.
| Document | Issued by | What the auditor looks at |
|---|---|---|
| RoHS test report | Third-party laboratory | Whether the homogeneous-material breakdown is complete, all ten substances covered, exemptions cited |
| RoHS Declaration of Conformity | Manufacturer | Signatory, models covered, directive version cited |
| REACH SVHC statement | Manufacturer / supplier | List version date, substance names and content, whether SCIP applies |
| SCIP notification number | Manufacturer (ECHA system) | Whether the notified item matches the exported model |
| Halogen-free test report | Third-party laboratory / laminate supplier | Cl and Br separately and combined, test method, level covered |
| Material declaration (BOM level) | Manufacturer | Coverage line by line, missing part numbers |
| Supplier environmental commitment | Upstream supplier | Validity period, obligation to notify changes |
First, the model on the report does not match what is actually built. The report names a "representative model" or a series; production later changes supplier or laminate and the report is not updated. Nothing shows at document level, but the moment a customer sends a sample to a third party it becomes a documentation falsification — far more serious than a technical nonconformity.
Second, incomplete coverage. One auxiliary item on the BOM — a label, a thermal pad, conformal coating, solder wire — without an environmental report holds the entire declaration hostage. Work through the BOM line by line when building the material declaration, and fill every gap. Do not hide behind "main materials".
The hard part of environmental compliance is never the testing. It is whether the evidence chain stays connected to the batch that actually shipped. Complete documents, matching versions and change notices that keep up make a customer audit a formality; one missing link means weeks spent producing a report that should have existed three years earlier.
