RoHS directive on imports of electronics from China

By | October 24, 2020

RoHS is an EU directive that applies to the manufacture and import of electronics. In short, RoHS sets limit values ​​for certain heavy metals in electronic components and solder. In order for an electronic product to be sold within Sweden and the rest of the EU, the product’s components must meet RoHS.

The difficulty lies in the fact that far from all suppliers in China have the experience and knowledge required to meet RoHS in the manufacture of electronics

What is the RoHS Directive?

What is the RoHS Directive

RoHS stands for Restriction of Hazardous Substances Directive and its purpose is to limit the content of products containing the following substances:

  • Mercury (Hg)
  • Cadmium (Cd)
  • Lead (Pb)
  • Hexavalent chromium (Cr6 +)
  • Polybrominated biphenyls (PBBs)
  • Polybrominated diphenyl ethers (PBDE)
  • Bis (2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (GDP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

These substances are found in a variety of materials, including solder, PVC plastics, paints, batteries and metal components. The EU has good reasons to impose restrictions on these substances. They are toxic and have a negative impact on both humans and the environment.

The EU has also made things a little easier for us. As of 2013, the RoHS directive is part of the CE. This means that an electronic product that is approved in accordance with the CE directive must also comply with RoHS.

CE in turn also requires that certain documentation is in place at import:

  • Declaration of Conformity
  • Technical file
  • Test reports (eg RoHS and Low Voltage Directive)

In addition, CE marking is also required on the product, packaging and in the manual.

Products that must comply with the RoHS directive

Almost all electronic products must be manufactured in accordance with the RoHS directive. This includes, among other things:

  • Large household appliances (eg refrigerators and air conditioners)
  • Small household appliances (eg microwaves and coffee machines)
  • Computer and communication equipment (eg laptops and tablets)
  • Consumer electronics (eg LED screens and Blu ray players)
  • Lighting (eg LEDs and light bulbs)
  • Power tools (eg drills and blowers)
  • Electric toys and sports equipment (eg exercise bikes)
  • Vending machines (eg vending machines)
  • Medical devices (eg heart rate monitors)
  • Semiconductor components (eg alcohol testers)

In practice, all electronic products must comply with RoHS. If you plan to import electronics from China, according to, it is best to always assume that the product must be approved according to the RoHS directive.

Most suppliers in China cannot manufacture RoHS products

In order for a product to meet RoHS, it is required that the factory only orders electronic components from subcontractors who can specifically deliver RoHS components. In many cases, components are manufactured both as RoHS and non-RoHS, where RoHS components are used specifically for products to be sold within the EU.

However, RoHS components are more expensive than those that do not meet RoHS, which is why there is also a demand from non-EU countries for components that are not RoHS components.

Example: RoHS in the manufacture of wristwatches

Quartz movements (Quartz Movements) are counted as electronic components and must therefore meet RoHS. All major Japanese watch manufacturers, such as Miyota and Seiko, only manufacture watches that meet RoHS. However, there are many Chinese watchmakers whose products do not meet RoHS.

If you are going to make watches in China, it is therefore critical to inform your factory that they should only order movements from Miyota, or another supplier of RoHS movements.

RoHS lab tests

A RoHS lab test verifies if the product meets the RoHS directive. In short, the test lab analyzes heavy metals to check whether the amount of heavy metals is below the limits set by the EU for the RoHS directive.

The following companies may offer RoHS lab tests:

  • QIMA
  • SGS
  • Intertek
  • Bureau Veritas
  • TUV

Cost of RoHS testing

As a rule, the test companies charge per component. The price per component starts from around 10 to 20 US dollars.

Test reports from supplier

It may seem easier and cheaper to use an old RoHS test report from the supplier. However, this is rarely an option as the authorities rarely accept test reports that do not apply to your particular product. Even if the product that RoHS tested is identical, outwardly, it does not mean that exactly the same components were used.

Other lab tests

Note that there are several other EU directives that cover, among other things, electrical safety, radio communication and EMC. Thus, RoHS is not the only thing to keep in mind when importing electronics from China.