Check a homogeneous-material concentration against Directive 2011/65/EU as amended by 2015/863. Verdict (PASS / FAIL / EXEMPT) with Annex III/IV exemption lookup, GB / EU / US jurisdictional split, and a cited compliance audit trail your SMB technical file can keep for the mandatory 10 years.
Laptops, routers, mobile phones
Always the homogeneous material level (Art. 4(1) Dir. 2011/65/EU). Never the whole assembly.
Indicative compliance check based on Directive 2011/65/EU as amended (RoHS 3 phthalate addition, Delegated Directive (EU) 2015/863). Not legal advice. Verify exemption status at the official sources before placing product on market.
RoHS thresholds apply at the homogeneous-material level, not the part or product level. A homogeneous material is one of uniform composition throughout that cannot be mechanically separated into different materials. SMB sourcing managers routinely conflate "part" with "homogeneous material"; XRF tests at the part level routinely under-report substance concentration.
Article 7(b) of Directive 2011/65/EU requires the technical documentation and EU Declaration of Conformity to be retained for 10 years after market placement. Manufacturers should link BOM, component declarations, and conformity assessment records to the corresponding DoC and keep them all for the same 10-year window.
GB RoHS (SI 2012/3032) diverged from EU RoHS after IP completion day (31 Dec 2020). EU exemption amendments published after that date are not automatically incorporated into GB. Northern Ireland continues to follow EU RoHS under the Windsor Framework (CE + UKNI marking). The US has no federal RoHS analogue — California has a narrower parallel rule via the Electronic Waste Recycling Act 2003.