RoHS and REACH: What to Ask For in Writing

A simple product with a long material list

A warming plate looks like three materials: a ceramic or silicone top, a plastic housing, a cable. Open it and the list grows — glaze on the ceramic, pigment in the silicone, pressure-sensitive adhesive under the heating film, solder on the controller board, insulation on the internal wiring, copper in the coil if there is one, printing ink on the housing, and the cardboard and foam around the whole thing. Substance restrictions apply part by part, not product by product, which is why a single sentence saying "RoHS compliant" is close to meaningless as evidence.

Two distinct regimes sit behind the paperwork. One restricts the presence of certain substances in electrical equipment. The other requires information about substances of concern to flow along the supply chain and to be passed on to customers on request. A buyer needs both, and they arrive as different documents.

Restricted substances versus declared substances

The restriction side is answered by test reports on materials and by a manufacturer declaration covering the bill of materials. The declaration is only as good as the material list behind it, so the useful question is not "are you compliant" but "which supplier declarations sit behind this statement, and for which part numbers".

The declared-substance side is answered by communication, not by testing. Suppliers are expected to tell you whether an article contains a substance on the candidate list above a threshold, and to give enough information for safe use. In practice this arrives as a questionnaire return or a database entry per part. It is a lower bar than a test report and a different document type; do not accept one as a substitute for the other.

Homogeneous material reports and what they actually cover

Testing is done on homogeneous materials — a single material that cannot be mechanically separated — so a report on "the housing" may cover several materials, and a report on "the surface" may cover the ceramic body, the glaze and the pad underneath as separate items. When a supplier sends one report titled with the product name, the first thing to check is which materials inside it were actually sampled.

A useful report names the material, the part it belongs to, the sample preparation, and the date. A less useful one lists the product and a row of passes. Both may be truthful; only the first can be mapped onto your bill of materials.

What to request, part by part

Part	Materials involved	Document to request	What to verify
Ceramic plate	Body, glaze, decoration	Material test report plus declaration	Whether glaze and decoration were sampled separately
Silicone top	Base polymer, filler, pigment, catalyst	Material report plus full declaration	Pigment and catalyst coverage
Heating film	Carrier, resistive layer, adhesive	Supplier declaration, report if available	Adhesive is often omitted
Controller board	Laminate, solder, components	Assembly declaration plus report	Solder alloy and any rework
Cable and plug	Conductor, insulation, jacket	Material report per material	Jacket and insulation listed separately
Housing and print	Resin, flame retardant, ink	Declaration plus report	Ink and any recycled content

The parts that get missed

Three omissions recur. The first is the adhesive that bonds the heating film to the substrate: it is thin, hidden and rarely sampled, and it sits directly under the hottest part of the product. The second is the pigment and catalyst package in a coloured silicone top, which is a different material from the base polymer and often sourced separately. The third is the printing on the housing and the coating on any metal trim.

Packaging deserves its own line. Cartons, inserts, bags and tape fall under a separate packaging regime in many markets, and the declaration for the product does not cover them. If your channel asks for packaging material statements, request them in the same email rather than in a second round.

A declaration is not a test report

The boundary to hold: a manufacturer declaration is a statement of responsibility, not a measurement; a test report is a measurement of the samples submitted, not of every unit shipped; and neither of them is a certificate issued by an authority. A supplier can be fully compliant and still have a thin file, and a supplier with a thick file can still ship a substituted material after a cost-down.

There is also a scope boundary inside this topic. Substance restrictions say nothing about electrical safety or electromagnetic behaviour; those belong to the CE, EMC and LVD file. Whether the glaze on a food-contact surface triggers an additional food-contact assessment, and whether the silicone top needs its own sampling plan, are questions for a laboratory and for your importer's compliance adviser — put them in writing and keep the answer.

Questions to put to a supplier

Can you send material reports per homogeneous material, not one report per product name?
Which parts are covered by your own declaration, and which rely on a sub-supplier's statement?
Were the glaze, the silicone pigment package and the film adhesive sampled, and when?
Do you hold declared-substance information per article, and can you pass it on within the required timeframe?
Which material substitution would trigger a new declaration, and who signs it?

Next step

Build the material table above into your RFQ so the answer arrives in a fixed shape. For a copy of the table we use, write to contact.

Prepared for desk-warming sourcing briefs. Numbers shown are placeholders; request measured data per model from the supplier.