RoHS does not have an official “RoHS mark” that can be placed on products. On the market there are all kinds of stamps with the words “RoHS”, “RoHS compliant”, “100% RoHS” – most of which are printed by sellers themselves, with no basis in the Directive. This not only confuses buyers but also creates legal risks when the content printed on the product is considered misleading.
This article clarifies three things: What RoHS is represented by according to the law, what content should and should not be printed, and how to handle when customers or exchanges request to see the “RoHS mark” on goods.
1. RoHS does not have its own mark: what is affixed is the CE mark
RoHS is a Directive that belongs to the group of CE marking requirements. Enterprises responsible for conformity must evaluate the product according to the requirements of the Directive, prepare technical documents, sign a declaration of conformity and affix the CE mark to the product. The CE mark is a way of demonstrating compliance, not the “RoHS mark”.
Therefore, when European partners ask about the “RoHS mark”, the technically correct answer is: CE mark with a declaration of conformity citing Directive 2011/65/EU, along with corresponding technical documents.
Exceptions to know: Some non-EU markets have their own labels that are mandatory — for example, environmental shelf-life labels and product substance lists according to Chinese regulations. This is the regulation of that market, not the EU “RoHS mark”.
2. What should be printed on products and packaging?
| Content | Should it be printed? | Note |
|---|---|---|
| CE mark in correct size and position | Required for in-scope products | Must be commensurate with product size, must not be obscured, and must not add decorative details |
| Manufacturer’s name and address | Required | If manufactured outside the EU, additional importer information is required |
| Product code, batch code, serial number | There should be | Helps with retrieval when review or recall is needed |
| The text “RoHS compliant” | Not required | If printing, make sure there are documents to prove it; Not to be used in place of a declaration of conformity |
| “100% RoHS”, “RoHS certified”, “RoHS certificate” | Shouldn’t | Easily seen as misleading: there is no RoHS certification in the sense of a certification body |
| Third-party certificate number | Only if it’s real | Must be correct number, correct scope, correct validity period |
3. Why is the word “RoHS certified” risky?
According to the usual understanding of the EU conformity system, RoHS does not have a mechanism for certification by a designated organization. Third party may test and issue test report; Businesses can hire an assessment organization to assist in preparing documents. But the responsibility for conformity still lies with the manufacturer or importer who signs the declaration of conformity.
Printing “RoHS certified” on a product or post may be considered a false claim, and falls within the group of practices covered by the EU’s unfair trade practices regulations. The risk does not come from the word “RoHS” but from implying that there is an organization guaranteeing compliance, when in fact there is not.
4. When customers or exchanges ask to “show the RoHS mark”
This is a very common situation. Treatment should follow three steps:
- Brief explanation: RoHS is demonstrated through CE marking and declaration of conformity; does not have a separate RoHS mark according to EU law.
- Submit a replacement set of documents: Declaration of conformity with reference to Directive 2011/65/EU, test report according to homogeneous materials, photo of CE label on actual product.
- If the customer still requires an inscription on the label: Neutral information such as “Compliant with Directive 2011/65/EU (RoHS)” can be printed on packaging or documents, with supporting documentation — avoid words such as “certified”, “100%”, “approved”.
5. Five common label errors
| Error | Consequences | How to room |
|---|---|---|
| CE marking is too small or covered by a secondary label | Considered non-compliance with marking requirements | Check the actual label image before running production |
| Use fake CE markings with added letters or patterns | Label is disabled | Just use the correct standard shape, no additional details |
| Missing importer information | The responsible party in the EU cannot be identified | Print with importer’s name and address when produced outside the EU |
| Print “RoHS certification” when only test report is available | Risks being considered misleading | Use neutral expressions |
| English labels on products sold to markets that require the local language | Lack of language requirements for attached documents | Prepare instructions and warnings in market language |
6. Labels according to other market requirements
- China: There are separate label requirements for environmentally friendly shelf life and a declaration of substances contained in the product according to this country’s label standards.
- Japan: The labeling program follows Japanese industrial standards with two label branches, depending on whether the product contains substances that exceed the limit or not.
- Korea: Integrated regulatory framework for substance withdrawals and restrictions, labeling requirements and information according to domestic regulations.
Common point: these labels are requirements of each market and do not replace the CE mark when goods enter the EU.
7. Frequently asked questions
Can the word “RoHS” be printed on the product packaging?
Not absolutely prohibited, but must ensure that the content is not misleading and has proven records. The safe way is to put the CE mark and manufacturer information on the product, and RoHS information is stated in the accompanying documents and declaration of conformity.
Customers request to write the testing laboratory’s certificate number on the label, should we do that?
You should only do this when the number is real, valid and within the correct testing range for that product. The certificate number of a test does not mean that the entire product is certified.
Can products that are not covered by RoHS be CE marked?
CE marking may only be affixed when the product falls within the scope of at least one Directive requiring CE marking. If the product does not fall within any scope, CE marking is incorrect.
Does the CE label need to include the number of the designated organization?
For some product groups that require third-party evaluation, the CE mark must include the number of the designated organization. With RoHS, manufacturers’ self-assessment mechanisms are common.
The floor requires a photo of the label, how should I take one?
Clearly capture the CE mark, manufacturer’s name and address, import information, product code — on the actual product or actual packaging, do not use staged photos lacking details.
8. Conclusion
There is no “RoHS mark” under EU law; What is affixed is the CE mark, and RoHS compliance is proven by technical documents and a declaration of conformity. The simpler and more compliant the label, the less risk.
Three things to do: finalize label content before production; remove guarantee words such as “certified”, “100%”; and prepare a set of documents to respond when customers or exchanges request to “see the RoHS mark”.
References
- Directive 2011/65/EU and amending documents (conformity assessment, declaration of conformity, CE marking).
- EU framework regulations on CE marking requirements and unfair trade practices regulations.
- China’s regulations on environmentally friendly shelf life labels and substance declaration tables.
- Japanese industrial standard on labeling of substances in electrical and electronic equipment.
Related articles
- Declaration of conformity (DoC) and CE marking for RoHS: who signs, for which products, what if it’s wrong?
- Is there “RoHS certification”? Distinguish between test report – certificate – declaration of conformity
- EFUP label and Chinese RoHS mark: read the correct table SJ/T 11364-2024
- What is RoHS? Complete guide to Directive 2011/65/EU and its 10 restricted substances
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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