Get Fast, ISO 17025 Accredited ROHS Testing Services

RoHS Testing, or Restriction of Hazardous Substances Testing, is an important compliance activity for electrical and electronic equipment (EEE) sold into regulated markets. It verifies whether restricted hazardous substances in a product or its materials remain within the applicable concentration limits. For manufacturers, importers, exporters, OEMs and component suppliers, RoHS evidence can support product conformity, customer approvals, technical files, regulatory assessments and environmentally responsible product design.

In 2026, RoHS compliance requires more than simply obtaining a generic “RoHS certificate.” For the European Union, conformity is the responsibility of the manufacturer and is supported by technical documentation, an EU Declaration of Conformity and CE marking where the Directive applies. Testing is one important source of technical evidence. In India, RoHS-type requirements are addressed through Rule 16 of the E-Waste (Management) Rules, 2022, together with subsequent amendments and specified exemptions.

Instacertify supports manufacturers, importers, exporters, suppliers and sourcing organizations with RoHS testing and compliance coordination through laboratories accredited to ISO/IEC 17025, with the exact accreditation scope verified for the required testing method and product/material.

What Is RoHS Testing?

RoHS Testing is the laboratory evaluation of electrical and electronic products, components or homogeneous materials to determine whether specified restricted substances are present above permitted concentration levels.

The principal EU RoHS framework is Directive 2011/65/EU, commonly known as RoHS 2, as amended. Annex II currently restricts 10 substances: Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium [Cr(VI)], Polybrominated Biphenyls (PBB), Polybrominated Diphenyl Ethers (PBDE), DEHP, BBP, DBP and DIBP. The maximum concentration values are generally 0.1% by weight in homogeneous material for eight of these substances and 0.01% for cadmium.

The important point is that RoHS limits are assessed at the homogeneous-material level, not simply against the total weight of a finished device. A single product can therefore contain many separate materials that require evaluation, such as plastics, coatings, solder, wires, metals, PCB materials and other components.

RoHS Restricted Substances and Maximum Limits

These concentration values come from Annex II of the EU RoHS framework and its amendment introducing the four restricted phthalates.

A laboratory report should also clearly distinguish between total chromium and hexavalent chromium. XRF screening can determine total chromium, but it does not by itself establish the concentration of Cr(VI). Where necessary, a specific Cr(VI) analytical method is required.

Which Products Need RoHS Testing?

RoHS requirements primarily concern electrical and electronic equipment falling within the applicable regulatory scope. Under the EU Directive, the categories include household appliances, IT and telecommunications equipment, consumer equipment, lighting equipment, electrical and electronic tools, toys and sports equipment, medical devices, monitoring and control instruments, automatic dispensers and other EEE.

Typical products evaluated for RoHS compliance include:

• Consumer electronics and smart devices
• Computers, laptops, networking equipment and peripherals
• Chargers, adapters and power supplies
• Printed circuit boards and electronic assemblies
• Cables, wires and connectors
• LED and other electronic lighting products
• Electrical appliances
• Industrial electronic equipment
• Telecom and IoT equipment
• Automotive and EV electronic components
• Batteries and electronic accessories where applicable
• Medical and laboratory equipment subject to the applicable RoHS framework
• Electronic components supplied to OEMs

Whether a specific product is legally within scope should always be determined against the legislation applicable to the destination market. Product function, configuration, intended use and applicable exclusions or exemptions can affect the analysis.

Is RoHS Testing Mandatory in India?

India has its own regulatory framework for hazardous substances in EEE through the E-Waste (Management) Rules, 2022, which came into force on April 1, 2023. Rule 16 addresses the reduction in the use of hazardous substances in electrical and electronic equipment and related components, consumables, parts and spares listed in Schedule I.

Under Rule 16, the Indian framework specifies limits of 0.1% by weight in homogeneous materials for Lead, Mercury, Hexavalent Chromium, PBB and PBDE, and 0.01% for Cadmium. The Central Pollution Control Board's FAQ confirms these limits and identifies Rule 16 as the relevant RoHS provision under the E-Waste Rules.

However, it is not accurate to describe Indian RoHS requirements as identical to EU RoHS in every respect. India has its own E-Waste Rules, product schedules and exemptions. The framework has also been amended since 2022. Therefore, manufacturers and producers should assess the current Indian provisions applicable to their particular EEE rather than relying on an older generic RoHS statement.

Important India RoHS Updates Relevant in 2026

The Indian RoHS provisions have changed through amendments and specific exemption schedules.

The January 2023 amendment provided exemptions for specified applications involving solar photovoltaic equipment and medical equipment. The July 2023 Second Amendment subsequently introduced additional structures for RoHS exemptions, including Schedule II-A, II-B and II-C and time-bound provisions for certain equipment and parts.

For example, the July 2023 amendment established provisions under which specified Schedule II-C equipment placed on the market on or before April 1, 2025 could fall outside Rule 16(1), while certain corresponding components, consumables, parts and spares could benefit from a transitional provision until April 1, 2028 where RoHS-compliant alternatives were unavailable.

The March 8, 2024 amendment introduced changes concerning EPR certificate trading platforms and flexibility for certain return-filing timelines; it did not replace the basic hazardous-substance concentration limits in Rule 16.

This makes it especially important in 2026 to check the latest applicable exemption and product category before concluding whether a component or product must meet a particular RoHS requirement.

Is a “RoHS Certificate” the Same as RoHS Compliance?

Not necessarily.

For EU RoHS, there is no single EU-issued universal “RoHS certificate” that automatically certifies every product. The manufacturer is responsible for demonstrating conformity. The Directive requires manufacturers to prepare technical documentation, perform the applicable internal production control procedure, issue an EU Declaration of Conformity and affix the CE marking after conformity has been demonstrated. Technical documentation and the EU Declaration of Conformity must generally be retained for 10 years after the EEE is placed on the market.

A RoHS laboratory test report is therefore best understood as technical evidence supporting a compliance assessment, not as a substitute for the manufacturer's legal Declaration of Conformity.

In India, CPCB guidance also refers to self-declaration and the availability of technical RoHS documents for verification.

Why Choose an ISO/IEC 17025 Accredited Laboratory?

ISO/IEC 17025:2017 is the international standard for the competence of testing and calibration laboratories. It addresses laboratory competence, impartiality and consistent operation. ISO confirms that ISO/IEC 17025:2017 remains the current edition and was reviewed and confirmed in 2023.

For RoHS testing, accreditation should not be judged only by whether a laboratory has an ISO/IEC 17025 certificate. The scope of accreditation matters. The laboratory should be accredited for the relevant test methods, materials and analytes required for the assignment.

ILAC explains that laboratories accredited by accreditation bodies that are signatories to the ILAC MRA can have their accredited results recognized through the MRA framework. However, ILAC also notes that this does not mean every foreign regulator, purchaser or market automatically accepts every report; the applicable method, scope and local regulatory requirements still need to be considered.

How Is RoHS Testing Performed?

A robust RoHS testing program generally begins with identifying the product configuration and determining which materials require assessment.

The process may include:

1. Product and BOM Review: The product structure, bill of materials, technical specifications and material composition are reviewed to identify potentially high-risk materials.

2. Sampling and Disassembly: Representative samples are selected and, where necessary, separated into homogeneous materials. IEC 62321-2:2021 provides sampling, disassembly and mechanical preparation strategies for electrotechnical products.

3. XRF Screening: X-ray fluorescence can provide rapid screening for elements such as lead, mercury, cadmium and total chromium. The newly published IEC 62321-3-1:2026 expands the XRF screening method to additional elemental screening parameters, including total bromine, phosphorus, chlorine, tin and antimony.

4. Confirmatory Chemical Analysis: Depending on the result and regulatory requirement, laboratories may use ICP-OES, ICP-MS, AAS, GC-MS, colorimetric or other validated techniques.

5. Evaluation Against Applicable Limits: The analytical results are compared with the relevant legal limits, taking product category and applicable exemptions into consideration.

6. Test Report and Compliance Documentation: The laboratory issues the applicable analytical report. The manufacturer can then use the evidence as part of its technical documentation or customer compliance package.

RoHS Test Methods and IEC 62321

The IEC 62321 series is a major reference for determining restricted substances in electrotechnical products.

IEC 62321-3-1:2026 covers XRF screening and is an important 2026 development in the testing landscape.

IEC 62321-4:2013+A1:2017 specifies methods for mercury using CV-AAS, CV-AFS, ICP-OES and ICP-MS.

IEC 62321-5 covers cadmium, lead and chromium in polymers and electronics and cadmium and lead in metals using techniques including AAS, AFS, ICP-OES and ICP-MS.

IEC 62321-6 addresses PBB and PBDE determination in polymers using GC-MS and other techniques.

IEC 62321-7-2 provides quantitative determination of Cr(VI) in polymers and electronics using a colorimetric method, while IEC 62321-7-1 addresses Cr(VI) in corrosion-protection coatings on metals.

IEC 62321-8 covers determination of DEHP, BBP, DBP and DIBP, among other phthalates, in polymers using GC-MS-based techniques.

The appropriate method depends on the substance, material, concentration range, laboratory capability and regulatory/customer requirement.

XRF vs Chemical Testing for RoHS

XRF is valuable because it is rapid and can often be used for non-destructive or minimally destructive screening. However, it should not automatically be treated as a complete substitute for every RoHS analytical method.

For example, XRF measures total chromium rather than specifically proving Cr(VI), and elemental screening does not directly establish all restricted organic substances such as PBB, PBDE and the four restricted phthalates. IEC 62321 provides dedicated methods for these substances.

A competent laboratory therefore selects the analytical approach based on the material and the substance being assessed rather than applying the same test to every component.

What Documents Are Needed for RoHS Testing?

The exact documents depend on the laboratory and destination market, but a compliance assessment commonly starts with:

• Product name and model number
• Product specification or datasheet
• Bill of Materials (BOM)
• Component and material information
• Manufacturer/supplier details
• Product photographs
• Existing supplier material declarations, where available
• Previous RoHS or material test reports
• Applicable product standard or regulatory requirement
• Samples or representative material specimens

For EU compliance, testing evidence is only one part of the technical documentation package. The EU Declaration of Conformity and other technical records must also be maintained according to the applicable requirements.

IEC 62474 can also support supply-chain material declarations by providing requirements for reporting substances and materials and a common data-exchange framework for the electrotechnical industry.

What Is the RoHS Testing Process at Instacertify?

Instacertify coordinates RoHS testing for manufacturers, suppliers, importers and exporters based on the destination market and product requirements.

The engagement generally starts with a review of the product details and BOM. Samples are then arranged for testing through the appropriate laboratory. Depending on the product and scope, the laboratory may perform screening and/or confirmatory chemical analysis using applicable IEC 62321 methods.

After testing, the laboratory report provides the analytical results and relevant test information. Instacertify can then assist with understanding the results and compiling the appropriate compliance documentation for the intended market.

The current Instacertify service offering states that RoHS testing is coordinated through ISO/IEC 17025-accredited laboratories and supports component-level and BOM-level compliance requirements.

Why RoHS Testing Is Important for Manufacturers

RoHS testing can help manufacturers identify restricted substances before products enter mass production or reach the market. It can also strengthen supplier qualification, support customer audits and provide objective analytical evidence when material declarations alone are insufficient.

For complex electronics, the greatest risk may not exist in the finished product as a whole. It can arise from individual homogeneous materials such as solder, plastic housings, cable insulation, coatings, connectors, metal alloys or other components.

A structured BOM-based testing approach can therefore provide better compliance visibility than testing only the final assembled product.

2026 RoHS Compliance: What Has Changed?

RoHS is not a static compliance topic.

One notable technical development in 2026 is the publication of IEC 62321-3-1:2026, which updates XRF screening and expands the elemental scope of the method.

The EU has also continued to update its exemption framework. In September 2025, the European Commission adopted Delegated Directive (EU) 2025/2364 concerning lead exemptions involving steel, aluminium and copper. The amendments include new or revised exemption entries with different expiry dates, including dates extending into 2026 and 2027. The Directive provides that Member States apply the provisions from July 1, 2026.

A separate Delegated Directive, EU 2025/2363, updated exemptions concerning lead in glass and ceramic components, including new entries with expiry dates in 2027.

This means a product should not be assessed against an old exemption list copied from a previous report. The applicable exemption wording, product category and validity date should be checked at the time compliance is evaluated.

How Often Should RoHS Testing Be Repeated?

There is no universal rule that every product must automatically undergo a RoHS test every year.

A more defensible compliance approach is to reassess products when there are material changes that could affect compliance, such as a new supplier, revised BOM, replacement component, formulation change, new coating, solder change, manufacturing-site change or regulatory update.

Some customers may impose their own periodic testing requirements, and some companies may establish annual or risk-based testing programs as part of supplier quality management.

The testing frequency should therefore be based on applicable law, product risk, customer requirements, manufacturing changes and the organization's compliance-control system rather than an arbitrary one-size-fits-all interval.