“Is this batch of textile goods subject to RoHS?” — the question sounds simple, but it is the reason why many businesses make incorrect documents in both directions: either overdoing it (wasting money on non-applicable requirements), or underdoing it (omitting the regulatory framework that actually applies).
This article states the principles for determining the scope, compares the applicable framework for each product group and points out cases of “having electricity but not falling under RoHS”.
1. Original principle: RoHS only applies to electrical and electronic equipment
RoHS applies to devices that require electric current or electromagnetic fields to operate. Three decisive questions:
- Does the product require electricity or electromagnetic fields to operate?
- If so, is the part that creates that function a separate device or just an accessory?
- Is the final product in the group regulated as separate electrical and electronic equipment or just a part of another product?
If the first answer is “no”, RoHS does not apply — regardless of whether the product has a technical label or not.
2. The framework applies to each product group
| Product group | Does RoHS apply? | Alternate main frame |
|---|---|---|
| Textiles do not have electrical functions | No | EU chemical regulations on substance restrictions in textile products, product safety requirements, and individual label requirements |
| Shoe leather | No | EU substance restriction regulations, including hexavalent chromium limits in leather products; product safety requirements |
| The toy has no electrical function | No | Toy safety in the EU, destination market regulations, chemical requirements for toys |
| Toys with electrical and electronic functions | Yes, for the electrical part | At the same time, it must meet toy safety requirements |
| Clothing with LED lights or sensors | Yes, for the electrical assembly | Combine textile requirements and electrical equipment requirements |
| Shoes with lights or electronic modules | Yes, for the electrical assembly | Combination of leather chemical requirements and electrical equipment requirements |
| The bag has an electronic lock and charging pocket | Yes, for power module | Combines general requirements and electrical equipment requirements |
Worth noting: for shoe leather, the requirement for hexavalent chromium — which is often associated with RoHS — comes from the EU substance restriction framework for leather products, not RoHS. This is a common source of confusion when a business makes both leather goods and electronic goods.
3. Three cases of “having electricity but not under RoHS”
| Case | Why is it not within the scope? | Still what to do? |
|---|---|---|
| The ornament has a battery just to glow | In most cases, it is considered an accessory to the main product, not a separate device | Check product safety requirements and battery requirements; Confirm again if sold separately |
| Electrical accessories supplied with the device are not within the scope | May be in scope if sold separately or has its own function | Clarify the selling method and actual function of the accessory |
| Electronic parts installed in vehicles, machinery, and medical equipment | There is a separate frame for the final product | Apply the framework of the end product and customer requirements |
Pragmatic rule: if in doubt, ask the customer in writing what framework applies to the end product, rather than guessing from the product name.
4. Why do customers still ask about RoHS for textiles?
- General purchasing requirements: Many corporations use a request form for every product group, including the RoHS section.
- Broad interpretation: “RoHS” is used as a general name for a group of substance restriction requirements.
- There is an electrical part in the product: Many modern textile items have small electronic modules.
- Avoid risks: Customers want to be sure the supplier understands the scope properly before signing the contract.
The appropriate response is not “don’t have to do it” but: confirm whether the product has an electrical or electronic part, state which framework actually applies, and propose the corresponding set of documents.
5. Five questions you should ask your customers
- Does the product have electrical and electronic functions, and is that part sold separately?
- Is the main target market EU, US, Japan or many markets?
- Does the customer have a separate substance request form?
- Does the product come into direct contact with the user’s skin?
- Do customers require specific standards beyond legal regulations?
6. Frequently asked questions
So what documents do textile and garment products need?
Usually a test report requested by the customer for restricted substance groups applicable to textile materials, accompanied by a manufacturer’s declaration. Specific content depends on the market and customers.
What if the customer still requires a RoHS report?
Can be discussed to agree on appropriate standards for materials. If the customer requests it, it can be tested according to the restricted substance list for risky materials and clearly stated in the scope of application report.
Are shoe leather tested for hexavalent chromium?
Yes, but according to the substance restriction framework for leather products, not according to RoHS. Applicable limits and test methods are also different.
What about handbags with wireless charging modules?
The charging module has its own electrical function, so that part falls under the scope of electrical and electronic equipment. Need records for electrical parts, and records for leather or fabric materials.
How do you know if an electrical accessory is a separate device or an accessory?
Based on the actual function and how it is marketed: if the accessory can operate independently and is sold separately, it is likely to be considered a separate device.
7. Conclusion
RoHS only applies to electrical and electronic equipment. Textiles, footwear and toys without electrical functions are outside the scope of RoHS, but must still meet the target market’s other substance restriction frameworks.
Three things to do: clearly determine whether the product has electrical or electronic components; Record the applicable frame for each product code in the file; and confirm in writing with the customer before testing begins.
References
- Directive 2011/65/EU and its amendments (RoHS) — definition of electrical and electronic equipment and scope of application.
- Regulation (EC) 1907/2006 (REACH) — substance restrictions relating to textile, leather and consumer products.
- Directive 2009/48/EC on toy safety and the EN 71 series of standards.
- EU general product safety regulations for consumer goods.
Related articles
- RoHS scope of application: which products must comply, which products are excluded?
- Same toy, three sets of limits: RoHS vs EN 71-3 vs CPSIA
- How are RoHS and REACH different? Thresholds, scope and reporting obligations
- RoHS and ELV: two different sets of substance limits for electronics and automobiles
Discuss further
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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