Five common answers that don’t guarantee RoHS compliance
Many procurement departments face a real challenge: sourcing electronic components that actually comply with the RoHS Directive.
When requesting a declaration of compliance, it’s common to get answers that sound reasonable… but don’t actually prove anything.
Here are five typical supplier responses that don’t guarantee RoHS compliance, and that should raise a red flag:
1- “Our component is lead-free.” A good start, but RoHS doesn’t only regulate Lead. The directive sets limits on ten hazardous substances, including Mercury, Cadmium and phthalates. 
Don’t settle for “no Lead” — ask for full compliance.
2- “The component has CE marking.” This is a common mistake in applying the directives. Individual components (such as resistors, capacitors, or connectors) are outside the scope of RoHS and shouldn’t carry CE marking at all. If a supplier shows CE marking on the component itself, that’s not proof of compliance — it’s a sign of confusion.
3- “We’re ISO 14001 certified.” ISO 14001 shows that the company has an environmental management system in place, but it doesn’t mean the component complies with hazardous substance limits. This certification doesn’t replace RoHS-specific documentation.
4- “We comply with RoHS 2002/95/EC ” (old version). The directive has been updated since then, for example with the addition of 4 phthalates. Some suppliers still reference older versions, or claim an exemption applies… …that may no longer be in force or may not apply to the product. Always check the current version and whether any specific exemptions are actually being used correctly.
5- “Here’s our substance declaration by weight.” A list of substances and percentages doesn’t let you assess RoHS compliance unless it shows how those substances are distributed. RoHS requires assessment at the level of each homogeneous material in the product. Without that breakdown, there’s no way to know whether limits are exceeded in any part of the component.
Conclusion: RoHS compliance can’t be demonstrated with vague or generic statements. You need to understand the technical requirements and know exactly what documentation to request.
If you’d like help reviewing your suppliers’ documentation, you can reach us at contact@rohsornot.com
