Guide to Declaring RoHS Conformity in 2026

For electronics OEMs and contract manufacturers, a proper RoHS declaration of conformity isn't just paperwork — it's your legal shield and ticket to the market.

In 2026, RoHS conformity will matter more than ever, not only for ensuring global market access, but also for protecting legal liability against regulatory penalties and for meeting increasing customer requirements. With several RoHS exemptions set to expire, proactive planning is crucial. 

In this guide, we’ll clarify RoHS documentation requirements and declarations for manufacturers, helping you better prepare for 2026. Whether you're dealing with exemption expirations, supply chain complexities, or documentation audits, you'll find practical guidance to streamline your compliance process.

What Is a RoHS Declaration of Conformity?

Navigating RoHS compliance documentation can feel overwhelming, especially with regulatory changes on the horizon.

A declaration of conformity serves as your legal statement that a finished product meets all applicable RoHS substance restrictions. This document goes beyond a simple compliance claim — it represents your organization's formal commitment to regulatory adherence.

Definition and Scope

The RoHS declaration covers your complete product, including all components, subassemblies, and materials. Unlike component-level compliance statements from suppliers, your RoHS letter takes responsibility for the entire finished good as it enters the market.

Required Elements of Every RoHS Declaration

Your RoHS declaration template must include specific elements:

1. Manufacturer Details

Include the following for the entity placing the product on the market:

• Complete company name
• Registered address
• Contact information
  
  

2. Product Identification

Provide clear identifiers for the product(s) covered by the declaration, including:

• Specific model numbers
• Product names
• Variant specifications
  
  

3. Directives Cited

Reference the applicable legislation to ensure regulatory accuracy:

• RoHS Directive 2011/65/EU
• Any relevant amendments or delegated directives
  
  

4. Standards Used

List the technical standards applied during compliance assessment, such as:

• IEC 62321 series (testing methods)
  
  

5. Responsible Signatory

Identify the person with legal authority to bind the organization:

• Name
• Title
• Signature
  
  

Supporting Technical Documentation

Your RoHS declaration of conformity requires strong technical backup. This supporting documentation typically includes:

• Supplier material declarations
• Laboratory test reports for high-risk components
• Bill of materials (BOM) risk assessments
• Exemption justifications (where applicable)

Maintain clear traceability between your RoHS declaration and supporting evidence. Auditors and customers expect to see logical connections between your compliance claims and underlying technical proof.

Common Mistakes to Avoid

Missing product identifiers represent the most frequent error in RoHS declarations. 

Outdated directive references create compliance gaps. Ensure your RoHS compliance letter cites the current regulatory versions, not superseded directives from years past.

Unnamed responsible persons weaken your declaration's legal standing. Generic signatures or missing authorization details can invalidate your entire compliance statement during audits.

Vague exemption claims without proper justification expose you to regulatory challenges. If claiming exemptions, provide a specific technical rationale and regulatory references.

Roles and Responsibilities Across the Supply Chain

To avoid these common pitfalls and ensure a sturdy RoHS declaration, be sure to understand and define responsibilities across your entire supply chain. 

Each entity — from OEMs to component suppliers — plays a key role in maintaining compliance:

OEM Responsibility for the Final Declaration

As the OEM, you hold ultimate legal accountability for your RoHS declaration, even when outsourcing manufacturing or purchasing components from suppliers. This responsibility cannot be transferred to contract manufacturers or component suppliers through contractual arrangements.

Your RoHS declaration of conformity represents your organization's commitment to customers and regulators. While you rely on supplier data, the final compliance determination and declaration signature remain your responsibility.

Supplier Responsibilities

Component suppliers must provide part-level compliance statements supporting your RoHS declaration. These statements should include:

• Specific material compositions
• Test data when requested
• Clear identification of any applicable exemptions.

Suppliers should maintain updated documentation reflecting current product formulations and notify customers immediately of any compliance-impacting changes. Regular supplier audits help verify the accuracy of compliance claims supporting your RoHS letter of compliance.

Evidence Management and Traceability

Many manufacturers adopt a 10-year record-retention period (linking components, BOM, part numbers, and your RoHS declaration) to ensure traceability during audits and investigations. While this is widely accepted, you should verify applicable national transposition or guidance in your market.

Document version control ensures your RoHS declaration template reflects current product configurations. When components change, corresponding compliance documentation must be updated and properly referenced.

Change Control for Substitutions and Revisions

Require new compliance statements for any component substitutions, even when suppliers claim equivalent compliance status, such as:

• Part number changes
• Supplier switches
• Material formulation 

 Any one of these updates triggers documentation review requirements.

Create procedures requiring suppliers to alert you immediately of compliance-impacting changes. Delayed notifications can leave your RoHS declaration out of alignment with actual product composition.

2026 Landscape: Updates, Exemptions, and Risk Areas

Staying ahead of RoHS compliance requirements is critical as regulations evolve and exemptions expire or are renewed. Understanding high-risk substances, managing supplier data, and planning for potential changes can help ensure your products remain compliant. 

Here’s a breakdown of key focus areas and practical strategies to minimize compliance risks.

Exemption Expirations and Renewals to Watch

Several RoHS exemptions are set to expire or face renewal decisions in 2026. Lead-containing solders in specific applications and mercury in certain electronic components represent areas of particular uncertainty.

Monitor European Commission announcements on exemption renewals, as timeline changes can affect your product's compliance status. It’s also helpful to understand how RoHS overlaps with broader chemical regulations, such as REACH, to determine compliance. Build contingency plans for expiries affecting your product portfolio.

High-Risk Substances and Applications

Focus compliance attention on historically problematic areas. Surface plating operations often introduce restricted substances, while solder materials may contain lead under specific exemptions.

Pigments in plastic components and PVC cable insulation pose ongoing risks that require careful supplier verification. Ceramic components, particularly in high-temperature applications, may contain restricted substances requiring exemption justification.

Practical Risk-Reduction Tactics

Prioritize alternative materials where technically feasible, reducing dependence on exemptions that may expire. Pre-screen new suppliers using standardized compliance questionnaires.

Request updated RoHS declarations from suppliers annually, not just when problems arise. This proactive approach identifies potential issues before they impact your product compliance.

Minimizing Rework and Documentation Churn

Standardize your RoHS declaration template across product lines to reduce preparation time and ensure consistency. Build a reusable compliance library containing verified supplier statements and test data.

Centralize supplier compliance data in accessible systems, allowing for efficient documentation updates when product configurations change. This systematic approach reduces the administrative burden of maintaining current RoHS compliance letters.

Creating the RoHS Declaration: Template and Process

A clear, standardized process is essential for creating accurate and defensible RoHS declarations. When creating your RoHS letter of compliance, consider the following:

• Internal review: Before finalizing your document, confirm the accuracy of all product IDs and model numbers. Verify that your declaration aligns with the current BOM configurations.
• Exemption claims: Validate them against the current regulatory text and ensure you have the proper technical justification.
• Traceability: Check that your declaration can be traced back to supporting supplier statements and test data.
• Versioning and retention: Assign clear revision numbers to your RoHS declaration of conformity and maintain a version history for audit purposes. Archive all supporting documents and link them to specific declaration versions.
• Audit readiness: Prepare for customer or regulatory audits by organizing evidence in logical, accessible formats. Practice explaining your compliance approach and be ready to demonstrate the traceability between your claims and supporting evidence.
  
  

Strengthening Your RoHS Compliance Foundation

Creating a sound RoHS declaration of conformity requires careful planning, thorough evidence gathering, and clear communication with your suppliers. This document is more than just regulatory paperwork; it's a key to unlocking the EU market and a shield for your organization from liability.

By documenting everything, planning for regulatory changes, standardizing your processes, and holding suppliers accountable, you can build a strong foundation for your RoHS compliance strategy and the 2026 requirements.