Materials & Environmental
Restricted Substances to Track Per Homogeneous Material
Next Annex III Lead Exemption Expiry: 6(a) and 6(b)-I
From Customer Request to Audit-Ready RoHS Package with Certivo
Regulation Overview
The Restriction of Hazardous Substances (RoHS) Directive is one of the foundational EU chemical regulations for electrical and electronic equipment. RoHS 2 (Directive 2011/65/EU) restricts 10 hazardous substances and requires CE marking, technical documentation, and EU Declarations of Conformity.
RoHS applies to nearly all EEE across 11 product categories. If your product uses electricity or electromagnetic fields and is sold in the EU, RoHS almost certainly applies.
The challenge: compliance must be demonstrated at the homogeneous material level—not the product level. A single PCB contains hundreds of homogeneous materials, each requiring validation against all 10 substances. With Annex III and IV exemptions expiring on entry-specific dates, hazardous substance tracking is a full-time job.
Manufacturers of electrical and electronic equipment sold in the EU
Importers bringing EEE into the EU market
Distributors selling EEE in the EU (verification obligations)
Authorized representatives acting on behalf of non-EU manufacturers
Any company whose components are integrated into EEE products
Retailers and online sellers placing EEE on the EU market
Key Thresholds
Your product has been compliant for years because exemption 7(a) covers the high-melting-temperature lead solder in your power module. Under Delegated Directive (EU) 2025/1802, the general 7(a) entry now expires on 30 June 2027, and only seven application-specific sub-entries, 7(a)-I to 7(a)-VII, run to 31 December 2027. Lead-alloy entry 6(a) ends sooner, on 11 December 2026. Do you know which of your 3,000 components rely on which exemptions? One overlooked expiration means your CE marking is invalid.
You've requested RoHS declarations from 200 suppliers. 40% haven't responded. 30% sent PDFs that don't match your part numbers. 15% sent declarations referencing the old 6-substance RoHS. 10% sent expired certificates. Your compliance engineer spends 80% of their time chasing documents and 20% actually validating compliance.
RoHS compliance isn't at the product level—it's at the homogeneous material level. The solder on pin 47 of a 256-pin BGA is a separate compliance unit from the lead frame inside the same component. Your supplier's declaration says "RoHS compliant" but doesn't tell you actual substance concentrations or which exemptions they're claiming. When your customer asks for evidence, "trust us" isn't going to cut it.
Your customer in Germany needs RoHS evidence. UK needs UK RoHS. China needs China RoHS. Korea needs Korea RoHS. Same 10 substances, different documentation requirements, different formats, different languages—and they all want it this week.
Certivo In Action
Certivo in Action — RoHS Workflow
Features Tabs
From Manual Review to Exception Management
CORA-powered regulatory intelligence extracts substance data automatically. Your team focuses on exceptions that need human judgment—not manual hazardous substance tracking.
RoHS Documentation Acceleration
Generate complete, audit-ready RoHS packages in hours—not the 3-4 weeks of manual compilation.
Proactive RoHS Compliance Monitoring
When exemptions approach expiration, Certivo alerts your team instantly. Know which products are affected before compliance gaps appear.
Frequently Asked Questions
How does Certivo handle the 10-substance RoHS validation?
CORA-driven compliance intelligence parses supplier declarations to extract substance concentrations at CAS number level, then validates each homogeneous material against all 10 RoHS thresholds simultaneously. The system applies the correct threshold automatically (0.1% for most substances, 0.01% for cadmium) and checks exemption validity. You get a clear pass/fail/exemption-dependent status for every component.
Which RoHS lead exemptions expire in December 2026?
Two Annex III entries expire on 11 December 2026 under Delegated Directive (EU) 2025/2364: 6(a), lead as an alloying element in steel for machining and in galvanised steel; and 6(b)-I, lead in aluminium from scrap recycling, for EEE categories 1 to 7 and 10. Parts that rely on them need to move to a narrower entry, such as 6(a)-I or 6(a)-II where its conditions are met, or to a lead-free material. Certivo maps components to the Annex III and IV entries they depend on, tracks these dates, and flags declarations that still cite expiring entries.
How does Certivo handle multiple RoHS jurisdictions (EU, UK, China, Korea)?
Certivo validates a single supplier declaration against multiple RoHS regimes simultaneously. EU RoHS and UK RoHS have separate enforcement. China RoHS and Korea RoHS have different labeling rules. Certivo tracks these differences and generates jurisdiction-specific compliance packages from your common evidence base.
What document formats does Certivo accept for RoHS declarations?
Certivo accepts any format—IPC-1752A/B/C, PDF declarations, Excel spreadsheets, supplier-specific templates, even scanned documents. CORA-enabled analysis extracts substance data regardless of format, normalizes it, and validates against RoHS thresholds. No need to force suppliers into a single format.
How does Certivo compare to other product compliance management solutions?
Unlike spreadsheets or single-regulation tools, Certivo is supply chain compliance software combining automated supplier outreach, CORA-powered substance extraction, and multi-framework validation. RoHS, REACH, SCIP, and related regulations validate from a single supplier submission.