One of the most controversial questions in RoHS documents is: can the test report still be used if it is old? Short answer: There are no regulations setting a time limit for test reports, but that doesn’t mean old reports are always usable. The value of the report depends on whether the product and material source are still the same as at the time of testing.
This article covers how to self-assess old reports, the de facto milestones, and how to respond to customers who request “newer” reports — a common request that does not arise from the law.
1. Why does the law not set a deadline for test reports?
RoHS requires manufacturers to conduct conformity assessment based on the material and structure of the device, and then prepare technical documents to prove it. The test report is a piece of evidence in that file, not a license with an expiration date.
The law sets out: obligation to keep records for a certain period of time after the product is brought to market. This is a requirement about storage, not about reporting expiration.
2. Seven factors that make an old report no longer relevant
| Factor | Why lose value? | What to do? |
|---|---|---|
| Change material supplier | New materials may have different ingredients even though they have the same name | Request new declaration, try again for changed materials |
| Change product structure | Remove old material that no longer corresponds | Re-create the material list, try new materials |
| Change auxiliary materials: glue, ink, stamps, packaging | Groups of substances such as phthalates are often located in auxiliary materials | Include secondary materials in the evaluation list |
| Restricted substances list added | Old reports may not include new substances | Try supplementing the missing group of nutrients |
| The current exemption has expired | Exemption-based reporting is no longer correct | Review waivers, material replacements or extensions |
| Change production process | For example, changing from lead-based solder to lead-free | Try again using the new procedure |
| Test samples are not representative of production goods | Report correct model, wrong product | Test again on samples taken from mass production |
If all seven factors have not changed, the old report is still valid evidence, even if it is several years old.
3. Decision table: keep, add or try again?
| Situation | Proposed conclusion | Action |
|---|---|---|
| Products, materials, suppliers, processes remain constant; The report includes all applicable substances | Keep the report intact | Supplement the supplier’s unchangeable written confirmation |
| There are changes but only in auxiliary materials (glue, stamps, packaging) | Add changes | Try adding new material, keeping the portion unchanged |
| Report missing phthalate group while the product is already within the applicable mold | Supplement | Try adding 4 phthalates on soft plastic materials |
| Switch suppliers for high-risk materials (welds, plating, plastics) | Try again | Retest the material before delivery |
| Change structure or change production process | Try again with a new set of materials | Re-list materials and try the new list |
| Customers require reporting within a year or two | Market requirements, not laws | Written agreement: confirm unchanged, or retry according to the contract |
4. Why do customers still request new reports?
Most “reporting no more than two years” requirements come from customers’ internal policies, or from their supplier review cycles. Some reasonable reasons:
- Customers want to reduce their risk from substance list revisions or exemptions.
- Customers have encountered over-stocks due to suppliers changing materials without notice.
- The customer’s management system sets a fixed review cycle for every supplier.
The pragmatic approach is to negotiate based on evidence, not on legal arguments: provide written confirmation of no structural changes, include updated supplier data, and propose a risk-based testing schedule rather than a hard timeline.
5. Obligation to keep records: points to remember
For products that have been put on the market, businesses must keep technical records and declarations of conformity within the prescribed time period — the usual practice is ten years since the product was introduced to the market. In addition, when customers or authorities request, businesses must provide information proving compliance within a short period of time.
Practical consequences: old records should not be deleted; Even reports that are many years old are still valuable for demonstrating the condition at the time the product was placed on the market.
6. How to respond to customers in three situations
- Old report, no changes: Submit the old report, with a written confirmation of no change in materials and suppliers, and a comparison table with the current list of substances.
- Old report, with minor changes: Send the old report for the unchanged part, with additional test plans and specific completion deadlines.
- Old report, with major changes: Do not try to reuse it. Inform the retest schedule and provide interim screening results, if any, with a time commitment.
7. Frequently asked questions
Is a 3-year-old report considered expired?
There is no such regulation. But if during those three years there are changes in materials, suppliers or substance lists, the report may no longer be sufficient to demonstrate compliance for the current product.
If the supplier claims “no changes” is that enough?
There should be written confirmation, not just words. This document should clearly state the material code, version, confirmation date and commitment to notify when there are changes.
Is it necessary to retest when the EU adds new substances?
Need to review. The old report may still be correct for the substances tested, but if the new substance is missing, the missing substance must be tried to supplement it — this is the situation that occurs when the phthalate group is added to the restricted substances list.
Can a tier 2 supplier report be used as primary evidence?
Used as evidence in the sequence, but requires a trace: material code, supplier, date, corresponding sample. If the correct material being used cannot be traced back, the evidentiary value will be weak.
Should I retry periodically even if there is no change?
Periodic testing is recommended for high-risk materials and for products with multiple sources of supply. Frequency should be based on actual risk levels, not on hard timelines.
8. Conclusion
RoHS reports do not have an “expiry date”, but there are conditions of suitability: the structure, materials, supplier and substance list must still correspond to the goods being delivered. Instead of following a timeline, an assessment should be built according to change.
Three things to do: save the report by product code with date; Collect confirmation of no change from supplier; and have a review schedule associated with legal milestones of the export market.
References
- Directive 2011/65/EU and amending documents (conformity assessment, technical dossiers, storage obligations).
- EN IEC 63000 standard on conformity assessment documents for electrical and electronic equipment.
- Directive (EU) 2015/863 adds the phthalate group (example of how the list of substances has expanded over time).
Related articles
- Only sample RoHS report, no batch report—is it valid?
- RoHS technical records according to EN IEC 63000: what must businesses save and submit?
- How long must RoHS records be kept? Legal timelines businesses need to remember
- What happens if the RoHS exemption expires? Rules for spare parts and inventory
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Disclaimer
This article is an interpretive content compiled by us; not legal advice. Enterprises need to compare relevant documents/standards verbatim before applying them to specific products.
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