“How long to keep records” is a question that sounds administrative, but it determines whether a business can answer the market surveillance agency or not in a specific situation: a batch of goods sold three years ago is inspected, or a customer reopens records from an old project.
RoHS has clear record keeping obligations, and there are additional timelines that businesses must keep track of to know when records need to be updated. This article summarizes both groups: retention periods and milestones to remember.
1. Record keeping obligations according to RoHS
Manufacturers bringing electrical and electronic equipment to the EU market must keep it Technical records and declaration of conformity for ten years since the product was introduced to the market. The importer is also obliged to retain the declaration of conformity for the same period and present it upon request.
Two points need to be distinguished:
- Obligation to save: lasts ten years, calculated from the date of bringing the product to market, not from the date of manufacture.
- Obligation to provide: When requested by competent authorities, enterprises must provide information and documents proving compliance within a short period of time. This deadline does not allow businesses to collect documents from the beginning.
Practical consequence: records should be in a ready-to-send state, not in a “scattered in a retired technician’s email” state.
2. How long should each type of record be kept?
| Record type | Proposal deadline | Reason |
|---|---|---|
| Declaration of Conformity (DoC) | A minimum of ten years after being placed on the market | Obligations under the Directive; is the first requested document |
| Technical records by product code | Minimum ten years | Is the basis to prove the declared content |
| Material test report | According to technical records, at least ten years | Need to compare when old goods are inspected |
| Supplier’s material declaration | According to material life cycle, at least by technical records | Prove the data source of the conformity conclusion |
| Batch screening results | Shorter, usually several years | Used for internal quality control |
| Records of technical changes and supplier changes | According to product life cycle | Explain why the original records are still relevant or have been updated |
| Saved template | As agreed with the customer | Used when needing to compare facts with records |
3. Legal timelines that businesses need to follow
In addition to the retention obligation, there is another group of milestones associated with whether records are correct or not:
| Mold group | Content | Things to do |
|---|---|---|
| Mold expands the scope of application | When product groups that were previously out of scope become subject to compliance | Review product categories by product code |
| Application mold of phthalate group | Applies to each product group, some groups are later | Check if the old report includes the phthalate group according to the correct product group milestone |
| Expiration date of exemption | Each exemption line has its own deadline; Many lines have renewal dates in the period 2026–2027 | Monitor the list of exemptions in use, prepare alternative material plans |
| Milestone for transitioning exemption assessment mechanism | The transfer of exemption technical assessment activities to the European Chemicals Agency has its own transition milestones | Update the exemption tracking process, pay attention to announcement milestones |
| Application milestone for non-EU markets | For example, China’s new mandatory standards will take effect in the coming period | Prepare documents and labels according to each market’s requirements |
| Customer review cycle | Many customers request reports that are not too old | Record review milestones in the internal calendar |
4. How to organize records to save for ten years
- Organized by product code: Each product code has a record, inside divided by version.
- Marking the launch date to the market: The first batch delivery date or customs clearance date is used as the basis for calculating the retention period.
- Data Link: material list, supplier, test report, material declaration and effective date.
- Save all changes records: Material change records, supplier changes, process changes — this is evidence as to why the original records are still correct.
- Save in two places: originals and digital copies, with decentralized access.
- Schedule a review: tied to legal milestones and customer request cycles.
5. Five common mistakes
| Mistake | Consequences | How to room |
|---|---|---|
| Only save the test report, do not save the declaration of conformity | Missing required legal documents first | Save the signed DoC along with technical records |
| Calculate the expiration date from the date of manufacture | Save less than the obligation | Calculated from the milestone of bringing the product to market |
| Save by delivery batch | Cannot find records when retrieving by product | Organized by product code |
| Do not save the supplier’s material declaration | Unable to prove data source | Save with effective date and material version |
| Delete old records after changing products | Inability to respond to sold items | Only transfer to archive, do not delete |
6. Frequently asked questions
After ten years, can my records be deleted?
Regarding the retention obligation, after ten years since the product was placed on the market, the retention requirement under the Directive has been completed. But if the product is still on sale, under warranty or customers are still requesting it, the business should keep records longer.
Is the importer responsible for keeping records?
Yes. The importer must keep the declaration of conformity and provide it upon request; In addition, the manufacturer must ensure that the manufacturer has performed a conformity assessment.
Can digital records replace paper copies?
Normally, a digital version is accepted if it is complete, traceable, and has measures to ensure its integrity. It is important to pay attention to language requirements and the ability to present printed copies when requested by authorities.
Do I need to save product samples?
The law does not require sample retention in all cases, but many customers request it and the sample is very useful when comparing. The sample retention period should be agreed upon from the beginning.
When changing suppliers, do old records have to be kept?
Yes, because previously sold goods still need to be proven. The new profile complements but does not replace the old profile.
7. Conclusion
The obligation to keep RoHS records is ten years from the time the product is placed on the market, but the actual value of the records depends on how it is organized: by product code, with timelines, with change records.
Three things to do: clearly state the milestone of bringing the product to market for each product code; organize records by product code instead of by batch; and put export market legal milestones on the same review schedule as technical dossiers.
References
- Directive 2011/65/EU and its amendments (obligations of manufacturers and importers, record keeping period).
- EN IEC 63000 standard on conformity assessment documents for electrical and electronic equipment.
- Delegated Directives related to exemptions (expiration and renewal dates for the period 2026–2027).
- Directive (EU) 2025/2456 and transitional milestones related to the exemption assessment mechanism.
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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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