RoHS FAQs

 RoHS FAQs

A. General Information on RoHS

  1. What is RoHS and what are the key features of this regulation?
  2. What is meant by ‘homogeneous material’?

B. My RoHS obligations

  1. I am manufacturing only a small component for the end-product and I do not export my component to the EU. Do I still have to comply with RoHS?
  2. I am in the trading business for electrical and electronic products, but I do not manufacture these products. What are my RoHS obligations?
  3. My company manufactures packaging materials for electronics and electrical products. Since my products are not directly listed in the scope covered by the RoHS regulation, do I still have to comply with RoHS?

C. How to comply

  1. What do I have to do to comply with RoHS?
  2. How do I know whether I am RoHS-compliant?

D. Testing

  1. I am the manufacturer of an electrical product. Do I have to test every one of the components in my product?
  2. If I can self-declare compliance, why do I have to conduct product testing?
  3. Which components should I give priority to when deciding what to test?
  4. None of my processes involve any hazardous substances. Do I have to conduct any product testing?
  5. Besides testing, are there any other services available in the market that can help me comply with RoHS?

E. Process Certification – the IECQ QC080000

  1. My company manufactures a large range of components for various customers in the electronics industry. All our customers are now putting pressure on us to conduct testing on the components we supply to them. Is there any alternative way to show compliance without testing?
  2. What is the difference between IECQ QC080000 and other quality management standards like ISO 9001 or ISO 14001?

F. Documentation required

  1. How do I show that I am RoHS compliant?
  2. Is there any standard documentation / declaration format for RoHS?
  3. I wish to export my electrical and electronic goods to the European Union. Do I have to submit any documentation to the authorities for verification or approval?

G. Supply Chain management

  1. How can I ensure that my suppliers are RoHS compliant?
  2. Besides testing, what other methods can I use to verify that the materials / components I purchase are RoHS compliant?

H. Forms of assistance available to Singapore manufacturers and SMEs

  1. My company is a SME and we have limited resources to comply with RoHS. Is there any assistance from the government?

I. RoHS in Singapore

  1. Will there be any Singapore standards published to address RoHS requirements?

J. RoHS in different countries, including latest updates

  1. Is there any difference in the RoHS regulations in different countries?
  2. If I am compliant to EU RoHS, am I then automatically compliant to the RoHS regulations of other countries?
  3. I have heard that China RoHS requires testing. What are the China RoHS testing requirements? Who can provide such testing services in Singapore?

K. Product specific questions

  1. Do the RoHS regulations apply to air-conditioners?
  2. We have a switch / router for home use. Are there any requirements under J-MOSS for such a product?


A. General Information on RoHS


1. What is RoHS and what are the key features of this regulation?

Restriction of Hazardous Substances (RoHS) is an environmental directive implemented on 1 July 2006 by the European Union (EU).

RoHS limits the use of certain hazardous substances in electrical and electronic products.

Exports of major electrical and electronic products to the EU must not contain the following hazardous substances beyond a maximum permissible limit :
  • lead
  • mercury
  • cadmium
  • hexavalent chromium
  • polybrominated biphenyls (PBB)
  • polybrominated diphenyl ethers (PBDE)
Currently eight countries/regions have introduced similar RoHS regulations. They are :
  • America (only the state of California)
  • Australia
  • China
  • European Union (all member states)
  • Japan
  • Korea
  • Norway
  • Thailand
For more information, please see :

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2. What is meant by ‘homogeneous material’?

Homogenous materials refer to any single substance that is of uniform composition throughout and that can be separated mechanically through actions such as unscrewing, cutting, crushing, grinding and abrasive processes.

For example, a semi-conductor package contains many homogeneous materials which include :
  • plastic moulding material
  • tin-electroplating coatings on the lead frame
  • the lead frame alloy; and
  • gold-bonding wires

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B. My RoHS obligations


3. I am manufacturing only a small component for the end-product and I do not export my component to the EU. Do I still have to comply with RoHS?

Yes you do if you wish for your component to be usable in end-products that are to be exported to the EU. You will be required to ensure that your components do not contain more than the maximum concentration values of restricted substances, down to the homogenous material level.

As a supplier, you will be required to be compliant or risk losing business as buyers look for compliant suppliers.

You may also have to make changes to your operations and processes to ensure compliance.

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4. I am in the trading business for electrical and electronic products, but I do not manufacture these products. What are my RoHS obligations?

You will need to put in place key controls to ensure continuous compliance with RoHS requirements. Compliance involves ensuring that your products do not contain excessive levels of hazardous substances. You need to :
  • ensure existing equipment suppliers are compliant or switch to compliant suppliers
  • ensure that substances used in the products are compliant. This can be done by ensuring proper documentation of substance declarations from equipment suppliers
  • ensure RoHS requirements have been properly communicated through the supply chain
  • support your end customers who import and distribute in the EU by providing the necessary documentation such as declaration/testing information
For China, Japan and Korea, products containing hazardous substances must also be labelled appropriately. You need to ensure that the proper labels are affixed to the product according to the guidelines of the destination country.

For more information, please see :

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5. My company manufactures packaging materials for electronics and electrical products. Since my products are not directly listed in the scope covered by the RoHS regulation, do I still have to comply with RoHS?

Packaging materials are generally shipped together with the final product.

As such, although you are not strictly required to comply with RoHS, it is important to ensure that packaging materials do not contain the banned substances, so as to eliminate risk of contamination of the final product.

If you comply with RoHS requirements, you can also gain a competitive advantage as more and more buyers are seeking compliant suppliers.

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C. How to comply


6. What do I have to do to comply with RoHS?

Please refer to the Singapore RoHS Compliant Suppliers Directory (includes a Guide to Complying with RoHS)

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7. How do I know whether I am RoHS-compliant?

  1. Conduct self assessment on materials and your manufacturing process
  2. Obtain and review substance information and material declarations from suppliers
  3. Conduct testing to verify compliance when necessary
For more information, please see :

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D. Testing


8. I am the manufacturer of an electrical product. Do I have to test every one of the components in my product?

You should practice “due diligence”. Due diligence means that you can show that you did everything “a reasonable person would do” in order to comply with the law.

Testing and certification is one of the forms of due diligence.

You can carry out “selected analysis”, where you assess which products have the highest risk of non-compliance and give testing priority to those.

For products with lower priority, the least you can do is collect material declaration. Obtain information on the concentration of RoHS and other declarable substances in your materials from your suppliers or from the manufacturer of the materials.

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9. If I can self-declare compliance, why do I have to conduct product testing?

Testing of your products provides assurance of your compliance status. Certificates and test reports enhance the credibility of your self-declaration, giving your products a competitive advantage.

Product test certificates also provides evidence of your ‘due diligence’.

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10. Which components should I give priority to when deciding what to test?

You should test “high risk” components first, where there is high risk of the banned substances being present in the components.

List all components present in your product in a Bill of Materials, and then find out more about the substances present in each component. This will help you identify the ‘high risk’ components.

For more information, please see :

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11. None of my processes involve any hazardous substances. Do I have to conduct any product testing?

No, you do not, but you should still ensure that your tools and processes do not introduce hazardous contaminants into the final product. In such cases you may wish to conduct product testing periodically to verify that there is no contamination from your components and processes.

For more information, please see :

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12. Besides testing, are there any other services available in the market that can help me comply with RoHS?

Yes there are. The IECQ QC080000 is a voluntary quality management standard that helps your company identify, control, quantify and report the amount of hazardous substances in your processes.

By following this standard, it helps to show your due diligence in ensuring RoHS compliance. You can also choose to be audited and certified by an IECQ-recognised third party certification body.

The following certification bodies* offer the IECQ QC080000 certification services locally.
* This list is not exhaustive and does not constitute an endorsement of the listed service providers.

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E. Process Certification – the IECQ QC080000


13. My company manufactures a large range of components for various customers in the electronics industry. All our customers are now putting pressure on us to conduct testing on the components we supply to them. Is there any alternative way to show compliance without testing?

Yes, you can implement the IECQ QC 080000 quality management system for hazardous substances.

IECQ –HSPM QC 080000 is an internationally accepted system specifically designed for the management of hazardous substances. The management principles involved are very similar to those found in ISO 14001 and ISO 9001, making it easy for businesses to integrate RoHS management systems into existing quality management systems.

It is a process-based approach as it helps you control hazardous substances in the manufacturing process and eliminates the need to test every single batch produced.

This is in contrast to the product-based approach, which focuses on product testing and requires you to test every product you manufacture.

For more information, please refer to the following :

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14. What is the difference between IECQ QC080000 and other quality management standards like ISO 9001 or ISO 14001?

IECQ QC 080000 provides a dedicated Management Systems approach to dealing with hazardous substances.

While ISO 9001 provides confidence in suppliers’ overall quality, it does not contain technical elements or provide component-level quality assurance.

QC 080000 builds on the existing Generic Quality Management System Requirements of ISO 9001 and includes the requirements for managing Hazardous Substances that are in addition to the “base line” Management System requirements of ISO 9001.

To facilitate ease of use, QC 080000 uses the same Clause numbering as, and must be read in conjunction with, ISO 9001.

ISO 14001 does not have the dedicated focus of QC 080000 to hazardous substances management and does not establish absolute requirements for environmental performance, to prevention of pollution and to continual improvement.

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F. Documentation required


15. How do I show that I am RoHS compliant?

You need to produce documentary evidence of due diligence in ensuring compliance throughout your manufacturing and supply chain.

When the authorities check on RoHS requirements, they will always ask you to produce documentation on your processes or products. Documentary evidence may include :
  • supplier self-declarations
  • certificates and testing reports
  • audit reports
  • internal manufacturing records
Usually, the authorities will only resort to testing your products if they are dissatisfied with the documentary evidence. Otherwise, the availability and credibility of your documentation is sufficient to satisfy RoHS requirements.

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16. Is there any standard documentation / declaration format for RoHS?

There is no specified documentation format in the EU RoHS Directive but there have been voluntary standards and tools developed to help companies manage their documentation. For example :
  • IPC-1751 - Generic Requirements for Declaration Process Management
    IPC has developed a standard to simplify and standardise how the industry collects, tracks and discloses product material content information. This describes all generic requirements, including company information.
  • IPC-1752 - Materials Declaration Management
    This establishes electronic data formats and provides standardised forms to simplify the exchange of materials declaration information across the supply chain.

    You may download soft copies of these standards from the IPC website.
  • Joint Industry Guide (JIG)
    The JIG guide was jointly produced by The Electronics Industries Alliance (EIA), the Japan Green Procurement Survey Standardization Initiative (JGPSSI) and JEDEC. It provides a standardised list of relevant materials that require supply chain disclosure.

    A free soft copy of the JIG (PDF) may be obtained from the JEDEC website.

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17. I wish to export my electrical and electronic goods to the European Union. Do I have to submit any documentation to the authorities for verification or approval?

Yes. Under Restriction on the use of Hazardous Substances (RoHS), exporters of electrical and electronic goods must produce a product declaration for authorities if your products fall under the scope of RoHS.

You should also maintain in-house documentation to show due diligence in ensuring compliance throughout the manufacturing and supply chain.

If the product declaration is found to be unsatisfactory, the authorities will request for additional documentary evidence.

For more information, please see RoHS Enforcement Guidance Document (PDF).

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G. Supply Chain management


18. How can I ensure that my suppliers are RoHS compliant?

You should get materials declarations from your suppliers as documentary evidence of their compliance. You should also ensure that your suppliers have capable procedures in place to track and manage compliant products.

To verify that the supplier has met your requirements, you may also wish to :
  • conduct periodic audits on your suppliers; or
  • carry out selected analysis on their products
For more information, please see the Singapore RoHS Compliant Suppliers Directory (includes a Guide to Complying with RoHS).

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19. Besides testing, what other methods can I use to verify that the materials / components I purchase are RoHS compliant?

1. You can put in place routine checks on the supplier’s documents to ensure that you are getting RoHS compliant parts from your supplier. These documents include delivery orders, quality assurance reports, supplier’s self-declaration and RoHS test reports.

2. You can try to ensure that your suppliers have capable component traceability and tracking systems to prevent accidental mixing of compliant with non-compliant parts. RoHS compliant parts should also have an easily identifiable part number.

3. You can request for your suppliers to be certified to IECQ QC 080000. The QC080000 requires companies to put in place a system for hazardous substance-free product identification and traceability.

4. You can also conduct site audits on your supplier’s manufacturing premises to ensure that they have proper controls in place.

For more information, please see the Singapore RoHS Compliant Suppliers Directory (includes a Guide to Complying with RoHS).

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H. Forms of assistance available to Singapore manufacturers and SMEs


20. My company is a SME and we have limited resources to comply with RoHS. Is there any assistance from the government?

Yes, the government provides various forms of assistance.

Assistance Schemes
  • Technology Innovation Programme (TIP)
    Assistance is provided to SMEs developing technology innovations. If your RoHS compliance journey involves the creation of new or improved products and processes through the use of technology, you can tap on TIP for :

    1. Funds to hire technical experts from leading R&D institutions
    2. Funds to embark on technology innovation projects
    3. Consultancy and advice from Centres of Innovation at the local polytechnics
  • Local Enterprise Technical Assistance Scheme (LETAS)
    You can get a grant to hire external consultants to help you implement the IECQ-HSPM QC 080000 system – an internationally accepted system specifically designed for the management of hazardous substances.
Seminars & Workshops
  • ETAC organises awareness seminars and technical workshops regularly on RoHS. The latest workshops are “The RoHS Series 2008: RoHS Compliance and the Supply Chain”.

    It comprises four workshops to help enterprises develop strategies and acquire the tools to comply with RoHS. They will address operational issues and challenges that businesses face relating to information, quality and supply chain management. Workshops will be held in April, July, September and December 2008
  • Workshop schedules are available on the ETAC website.
Guidebook

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I. RoHS in Singapore


21. Will there be any Singapore standards published to address RoHS requirements?

Currently, there are no Singapore standards addressing RoHS requirements.

However, hazardous chemicals are controlled by the National Environment Agency’s (NEA) Pollution Control Department (PCD).

More information about hazardous chemicals control can be found at NEA’s Hazardous Substances Control website.

Singapore is also continuously monitoring the need for a Singapore standard based on worldwide developments of RoHS and industry demands.

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J. RoHS in different countries, including latest updates


22. Is there any difference in the RoHS regulations in different countries?

Yes there are differences.

The European Union (EU) : RoHS Directive is legally enforced by each EU member state within its borders. Products with more than the specified level of the 6 hazardous substances are banned from being sold or used in EU countries.

Japan : Has laws similar to EU’s RoHS. The same 6 substances are controlled, but there are no ban/restrictions on these substances. Products with levels of hazardous substances exceeding the specified limit must be marked appropriately.

California : Adopts EU’s RoHS for 4 of the 6 hazardous substances. Unlike the wide coverage of EU’s RoHS, California’s RoHS only affects 8 categories of new or refurbished “covered electronic devices” or video display devices.

China : RoHS laws are stricter than EU’s RoHS. Phase One requires imported products to be marked or labelled to indicate whether they contain hazardous substances. The “Environment-Friendly Use Period (EUFP)” must also be clearly labelled on covered products. Phase Two imposes substance restrictions and requires all imported products to be tested, approved and certified by laboratories designated by the Chinese authorities.

Korea : Adopts EU’s RoHS and extends it to automobiles. Products with levels of hazardous substances exceeding specified limit must be marked appropriately.

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23. If I am compliant to EU RoHS, am I then automatically compliant to the RoHS regulations of other countries?

No you are not. There are differences in the RoHS regulations in each country.

China’s RoHS laws are stricter than EU’s RoHS. Phase One requires imported products to be marked or labelled to indicate whether they contain hazardous substances. Phase Two imposes substance restrictions and requires all imported products to be tested, approved and certified by laboratories designated by the Chinese authorities.

Japan has laws similar to EU’s RoHS. The same 6 substances are controlled, but there are no ban/restrictions on these substances. Products with levels of hazardous substances exceeding the specified limit must be marked appropriately.

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24. I have heard that China RoHS requires testing. What are the China RoHS testing requirements? Who can provide such testing services in Singapore?

China RoHS will be implemented in 2 phases.

  1. In the 1st phase, you only need to self-declare the presence of hazardous substances in your products. Testing is not required yet, but you will need to indicate the substances present and label your products accordingly. Testing is only required in the 2nd phase.
  2. In the 2nd phase, a restriction will be put on the listed hazardous substances. Testing is to be done by laboratories designated by Chinese authorities to ensure that products comply. The list of designated laboratories has yet to be published. There are currently no known China-certified test centres in Singapore. Dates of implementation for phase 2 are also not known yet.

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K. Product specific questions


25. Do the RoHS regulations apply to air-conditioners?

Yes. Air-conditioners belong to one of the categories under electrical and electronic equipment that are under the EU directive, 2002/95/EC and its series of amendments (PDF).

For more information, please also see the Singapore RoHS Compliant Suppliers Directory (includes a Guide to Complying with RoHS).

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26. We have a switch / router for home use. Are there any requirements under J-MOSS for such a product?

The J-MOSS scheme (PDF) covers only 7 target products :
  • personal computers
  • air-conditioners
  • television sets
  • refrigerators
  • washing machines
  • microwave ovens
  • clothes dryers
The scheme only applies to items that make up the equipment body. As your switch/router is not part of the equipment body of any one of the 7 products, no content mark labelling is required.
Last Modified Date :15 May 2012