RoHS is a regulation that restricts substances in products. But in Europe, a new layer of requirements is being developed in parallel: requirements on eco-design and product information, which include Product passport no. This layer of requirements does not replace RoHS, but will change the way businesses demonstrate and retain regulatory data.
This article describes the two parallel layers of obligations, what changes in filing practices, and what businesses should prepare for now.
1. Two layers of obligations: substance restriction and ecological design
| Criteria | RoHS | Request eco design & product passport no |
|---|---|---|
| Central question | Does the product exceed the restricted substance limit? | Does the product meet requirements for durability, repairability, recyclability, recycled content and accompanying information? |
| Main tools | List of substances, limits, exemptions | Design requirements by product group, digital product profile, and published information |
| Request type | Prohibited or limited at limit | Specification and information requirements, which may include material limitations |
| Evidence | Technical documents, declaration of conformity, test reports | Product data is structured, associated with product codes, and can be retrieved digitally |
| Applicable subjects | Electrical and electronic equipment | Each product group follows a work plan and has its own roadmap |
Point to remember: these two layers overlap, are not mutually exclusive. The product must still meet RoHS, and may also have to meet eco-design requirements if it belongs to a priority product group.
2. What will digital product passports change?
The core idea: instead of a stack of paper documents sitting in an internal file, product information is organized into structured data, tied to product codes, that can be retrieved digitally.
With RoHS compliance, this means:
- Material data needs to be standardized from the beginning: material code, detail code, data source, version.
- Data must be linked to specific products: not just in yearly folders.
- Evidence needs structure: Test reports and material declarations are organized by data fields instead of separate files.
- Information may be released publicly or at a limited level depending on the type of data and specific regulations.
3. Five practical impacts on businesses
| Impact | What changes? | What should I prepare? |
|---|---|---|
| Material data must be reusable | It is not possible to respond by resubmitting an old report | Build a material database according to detailed codes |
| Retrieve by product code | Questions will come by specific product code | Organize records by product code, not by batch |
| Requirements on material origin | Recycled content and material source may have to be declared | Start recording material source data from suppliers |
| Repair and recycling capabilities | Influence from the design stage, not just the testing stage | Incorporate dismantling and material separation criteria into design requirements |
| The role of the supply chain | Data from the supplier becomes part of the published record | Standardize declaration forms and change notification provisions |
4. Things that do NOT change
- RoHS remains in effect: Substance lists, homogeneous material limits and exemption mechanisms remain independent obligations.
- The manufacturer’s responsibility remains with the manufacturer: cannot switch to a supplier or e-commerce platform.
- The declaration of conformity still requires: Digitized data is an organization, not a substitute for liability.
- The principle of pre-market evaluation remains the same.
5. Four things to do immediately
- Standardize material codes and detail codes throughout the production and purchasing system.
- Convert regulatory documents into data format: At a minimum, there is a table linking the part number, material, supplier and test report.
- Include data terms in supply contracts: Requires material declaration in data form with clear fields.
- Track the roadmap by product group: Determine in advance which group your product belongs to and which milestones will apply.
6. Frequently asked questions
Does a digital product passport replace a declaration of conformity?
No. Declaration of conformity is a legal document signed by the manufacturer; A digital product passport is a way to organize and publish product information. The two things serve two different purposes.
Do small businesses have to worry right away?
There is no need to prepare large infrastructure right away, but you should start standardizing material codes and organizing records according to product codes. These are two useful things for all current compliance requirements.
Is material data publicly available?
Depending on the type of data and specific regulations: some information is public, some is only for authorities and supply chains. Businesses should classify data as soon as it is collected.
Does the new requirement apply to components sold separately?
The scope depends on each group’s product definition in the work plan. With components, pressure often comes indirectly through data requests from customers manufacturing the end product.
Where should I start if I don’t have anything yet?
Start from material data: create a table linking product code, detail code, supplier, test report and effective date. This is common ground for both current RoHS and upcoming information requirements.
7. Conclusion
RoHS asks about substances in products; The class requires eco-design and a digital product passport asking about product features and information. The two layers are parallel, not interchangeable — and require the same thing: material data standardized by product code.
Businesses that have organized records by product code and have a materials database will move to the new stage much more easily. Any business that still leaves records scattered in folders and emails will have to start over.
References
- EU regulations on eco-design for sustainable products and product group working plans.
- Directive 2011/65/EU and its amendments (RoHS).
- EN IEC 63000 standard on conformity assessment documents for electrical and electronic equipment.
Related articles
- How long must RoHS records be kept? Legal timelines businesses need to remember
- CE marking for electronics: RoHS, EMC, LVD — and why WEEE is a different story
- RoHS technical records according to EN IEC 63000: what must businesses save and submit?
- Material declaration according to IEC 62474 and IPC-1752A: what must the supply chain send and receive?
- Batteries and RoHS: why is the EU battery regulation the main application framework?
- RoHS and WEEE: one side restricts the substance, the other side is responsible for recall
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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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