How do you know whether a REACH or RoHS declaration is valid?

Check your supplier's REACH and RoHS declarations. Understand common wording, spot missing information and ask for a useful clarification.

Verca editorial teamGuidePublished: Last fact-checked: 8 min read

Short answer

Check who issued the declaration, whether it covers the correct part and what information the assessment is based on. Then read what the supplier actually confirms and any limitations. A heading such as “REACH/RoHS compliant” does not give you the full answer. If something is unclear, ask the supplier a specific follow-up question. This guide shows you how.

Key takeaways

  • Match the declaration to the part and revision you actually buy.
  • Distinguish the document date from the date of the information behind the assessment.
  • Read any caveats and references alongside the supplier's statement.
  • Keep a record of what the evidence answers, what is missing and who will follow up.

This content is a practical overview, not legal advice. Always verify the current legislation and the requirements that apply to your product. Research uses official primary sources; competitor content is used only to identify questions and content gaps.

Start with four simple checks

You ask a supplier for REACH and RoHS evidence and receive a signed PDF. It looks professional and has “compliant” in the heading. The next step is to see what it actually says about the item you buy.

Check four things:

  1. The issuer. Can you identify who is making the statement and which document revision you have? If in doubt, check with the supplier through a contact you already know.
  2. The part. Can you link the statement to the correct manufacturer's part number, variant and revision? If you and the supplier use different part numbers, the connection needs to be clear.
  3. The assessment. Which rules, substances or substance lists did the supplier use? What date does the information relate to?
  4. The answer. What is confirmed, what is excluded, and which attachments or reports need to be read with the declaration?

In this guide, “declaration” means a supplier's information about substances in products and components. A formal EU declaration of conformity under RoHS has specific content requirements.

The supplier's declaration is part of the evidence for your own assessment. Your company's responsibilities depend on its role and the rules that apply to the product. See REACH Article 33 and RoHS Articles 7, 9–11 and 13, and Annex VI.

What should the declaration say about REACH and RoHS?

REACH includes requirements to provide information about substances of very high concern in articles, as well as restrictions on certain substances. RoHS restricts certain substances in electrical and electronic equipment within its scope. A statement about RoHS therefore does not automatically answer the REACH questions.

The Candidate List is the EU list of substances identified as substances of very high concern, or SVHCs. When reading REACH evidence, check which substances on the list have been assessed and which parts the statement covers. Also check whether the answer addresses relevant substance restrictions or refers only to the Candidate List.

For RoHS, check which substances and materials the assessment covers and whether the supplier relies on an exemption. If so, ask for the exemption number and an explanation of how it fits the use, product category and relevant date. A date in an exemption list needs to be read alongside any renewal applications and subsequent decisions.

Sources for this comparison: REACH, Articles 33, 59 and 67 and RoHS, Articles 2, 4 and 5.

A combined supplier document can be useful if it clearly sets out the statement for each set of rules. Read more in our guides to REACH and RoHS.

Common wording and what to ask

Supplier declarations often use short phrases. Read them in the context of the whole document. A caveat may describe the limits of the supplier's knowledge.

WordingWhat to look forAsk the supplier
“RoHS compliant”Which parts are covered and whether the assessment relies on an exemption.Does this cover our part and revision? Do you use an exemption for it?
“To the best of our knowledge”The information behind the supplier's conclusion.Is the answer based on material data, information from your suppliers, testing or a combination?
“Not intentionally added”The statement concerns intentional addition. It does not, by itself, state a measured concentration.Do you have information on actual presence or concentration for the part we are reviewing?
“Not detected” or “ND”How the report defines the result and what the investigation covers.What does ND mean in this report? Which substances and sample were examined, and what detection or reporting limit is stated?
“All products”The product group covered and any exclusions.Does this include our variant, surface treatment and any custom configuration?
“Subject to change”How you will find out when the information changes.How do you notify us of changes that affect our evidence?

These phrases alone do not make a document acceptable or unacceptable. Ask about the information missing from the declaration you are reading.

Four common mistakes

1. Assuming a new date means a new assessment

A recently issued document may refer to an older confirmation date or substance list. Look for the dates of issue, update, testing and the information used in the assessment. Ask what was actually updated if this is unclear.

2. Assuming a general declaration covers your variant

A product-family declaration may need a list showing which parts it covers. A different surface treatment, material or custom configuration can affect its scope. Ask for confirmation for the variant you buy.

3. Reading the summary but not the report

A certificate may refer to a specific test report or state that it is valid only together with that report. Follow the reference. Check what was tested and how the sample relates to your part. Read “PASS” alongside the scope of the testing.

4. Reading limit values as measured concentrations

A table may show permitted limits, measured concentrations or both. Read the column headings and the explanation of abbreviations such as ND. If a concentration is given as a percentage, check what that percentage is based on. Ask whether it refers to the whole product, a part or a particular material.

RoHS concentration limits apply to homogeneous materials, such as a particular plastic or coating. An average for the whole product therefore does not answer the same question. See RoHS Article 3(20), Article 4(2) and Annex II.

Ask for the missing information

Identify the part, the document and the question you need answered. Use the connector below as an example.

Example: You buy connector K1, revision B. The supplier's combined declaration says “all products”, but you cannot find your variant in an attachment. The RoHS section mentions exemptions without identifying which one applies.

You could write:

We are reviewing connector K1, revision B, for use in our control unit. We have received your combined REACH/RoHS declaration, revision 2, dated 3 November 2026.

Please confirm that the declaration covers this part and variant. Does the RoHS assessment rely on an exemption? If so, identify it and explain how it applies to our part and use at the relevant date.

State the evidence and dated substance list or version of the rules behind your answer. Refer to any attachments or reports and identify anything that has not yet been assessed. Please also tell us how you notify us of changes affecting this information.

Replace the example's part, product and document details with your own. Remove questions you already have answers to. The wording is a suggestion, not a legally required template.

Follow up the supplier's answer

When the supplier replies, check whether the missing information has been provided. Continue with the connector in the example above:

1. Return to your questions

You asked two things: does the declaration cover connector K1, revision B, and does the assessment rely on a RoHS exemption? Read the reply against both questions.

2. Follow up anything still unclear

If the supplier only confirms that your variant is included, you have an answer to the first question. The exemption question remains. Ask for that answer rather than another general declaration. If the reply refers to an attachment or report, read that too.

3. Keep the reply with the declaration

Save the clarification so you and your colleagues can see which declaration and part it relates to. Briefly record what the reply clarified and any question still open. The next person can then pick up where you left off.

Keep the part, evidence and assessment together in Verca

Verca connects products, components, materials and supplier evidence. Documents and changes can be followed in context, so you can see which evidence the work is based on.

See how Verca connects product data and evidence. Start with one of your own declarations and a question that is still unanswered.

Frequently asked questions

How old can a REACH or RoHS declaration be?

Age alone does not determine whether a declaration can be used. Check whether the information still matches what you buy. Distinguish the document date from the assessment date and check the product revision, substance list and version of the rules covered. Ask the supplier to confirm what has changed since the assessment.

Does a caveat make a declaration unusable?

No, not by itself. Check what the caveat applies to. A reference to available knowledge or information from sub-suppliers helps explain how the statement was prepared. Then assess whether you need more information to answer your question.

Do I need separate documents for REACH and RoHS?

No. A combined supplier document can be useful if both assessments are clear. Check the part, scope and conclusion for each set of rules. If the document is also intended to serve as a formal EU declaration of conformity under RoHS, it must meet the specific content requirements. See the explanation of document types above.

What if the supplier only says “compliant”?

Ask a specific follow-up question. Identify the part and document revision you are reviewing and the missing information. Start with the gap that prevents your next decision, such as whether your variant is covered or which exemption is used.

Own your compliance