Manufacturer
The manufacturer controls design and production, prepares technical documentation and the declaration of conformity, applies the relevant marking and maintains production conformity.
Before Electrical Appliances Enter Great Britain or Northern Ireland
UK Appliance RoHS Restricted-Substance and Material Evidence Handoff
UK RoHS control is not completed by a supplier statement saying that a finished appliance is "RoHS compliant". The responsible businesses need product-specific technical evidence showing how restricted substances were controlled across relevant homogeneous materials, components and production revisions.
Yaoyuan can coordinate available legitimate factory-side BOM, component, supplier, declaration, report, artwork, production and change evidence for an approved wholesale order. The responsible manufacturer, UK importer and qualified advisers determine legal scope, conformity, exemptions, declarations, markings and market action. This page is general B2B procurement information, not legal or laboratory advice. Wholesale only. MOQ starts from 1000 PCS.
Direct Answer for UK Appliance Importers
What must the RoHS evidence prove?
Equipment within scope must not exceed the prescribed maximum concentration values for ten restricted substances in each relevant homogeneous material, unless a current exemption covers the precise application. The manufacturer prepares technical documentation and a declaration of conformity. The importer verifies the manufacturer's work, keeps the declaration and ensures the technical file can be provided to OPSS on request.
A finished-product test can be useful, but it is not automatically a complete material-control system. Plastics, solder, plated metal, wire insulation, coatings, printed circuit assemblies, motors, heaters, adhesives, pigments and accessories can each introduce different material risks. The evidence strategy should reflect the BOM and supplier chain of the exact production model.
Territory Comes First
Separate Great Britain from Northern Ireland before approving evidence
| Market route | Current RoHS position | Importer control | Common mistake |
|---|---|---|---|
| Great Britain England, Scotland and Wales | The UK RoHS Regulations apply through the GB route. GB operates its own exemption system. Current official guidance permits UKCA or recognised CE routes where the applicable conditions are met. | Confirm the GB manufacturer or importer, applicable exemption, technical documentation, declaration, marking and address. | Assuming every current EU exemption automatically has an equivalent GB exemption. |
| Northern Ireland | The NI RoHS route continues to follow the EU exemption system and uses CE, or CE plus UKNI where the relevant UK body route applies. | Identify the NI or EEA importer and preserve the NI technical-file, declaration and marking route. | Using UKCA alone for Northern Ireland or treating GB and NI as one evidence jurisdiction. |
| One product for GB and NI | The physical construction may be shared, but each territory's current legal, exemption, declaration and marking basis must remain valid. | Create one controlled model identity with territory-specific decision records. | Combining two declarations or exemption bases into an unclear generic certificate. |
Territory should be fixed before the buyer accepts a material declaration or test plan. A report produced for an EU route may contain useful laboratory data, but the responsible UK business still checks whether the product, model, materials, exemptions and legal references support the intended GB or NI placement.
Ten Restricted Substances
Control concentration at homogeneous-material level
| Restricted substance | Maximum concentration by weight in homogeneous material | Common evidence focus |
|---|---|---|
| Cadmium | 0.01% | Pigments, plating, contacts, stabilisers and specific electronic parts |
| Lead | 0.1% | Solder, alloys, glass, ceramics, PVC, paint and electronic components |
| Mercury | 0.1% | Switches, lamps, displays and legacy components |
| Hexavalent chromium | 0.1% | Metal coatings, passivation and corrosion protection |
| Polybrominated biphenyls | 0.1% | Flame-retarded plastics and polymer components |
| Polybrominated diphenyl ethers | 0.1% | Flame-retarded housings, cable insulation and electronic materials |
| Bis(2-ethylhexyl) phthalate | 0.1% | Flexible PVC, cables, plugs, gaskets and soft polymer parts |
| Benzyl butyl phthalate | 0.1% | Flexible polymers, adhesives, sealants and coatings |
| Dibutyl phthalate | 0.1% | Plasticisers, adhesives, inks and soft plastics |
| Diisobutyl phthalate | 0.1% | Plasticised PVC, polymer compounds and related materials |
Homogeneous material means a material that cannot be mechanically separated into different materials. It is not the whole air fryer, fan, blender or water pump. Testing only a mixed finished-product sample can obscure which specific material is above or below a limit and whether an exemption is relevant.
Model-Specific Evidence
Build a UK RoHS technical file that follows the actual BOM
| File layer | Factory-side evidence | Responsible-party decision | Release control |
|---|---|---|---|
| Product identity | Commercial model, electrical ratings, functions, plug, accessories, brand and production revision | GB, NI or both; manufacturer and importer identities | Labels, declaration and reports identify the same product |
| BOM and material map | Components, material descriptions, supplier names, part numbers and application | Homogeneous-material risk and evidence priority | No unreviewed part or supplier substitution |
| Supplier evidence | Current material declarations, component declarations, specifications and available reports | Evidence reliability, scope and need for additional testing | Issuer, date, model, material and revision are traceable |
| Testing | Controlled sample identity and available laboratory report | Test method, material selection, limits and result interpretation | Tested sample matches production construction |
| Exemptions | Exact material, component and technical application | Current GB or EU/NI exemption reference, scope and expiry | No generic or expired exemption copied into the file |
| Risk assessment | Component function, supplier history and change information | Why declarations, testing or other controls are sufficient | Decision and evidence owner are recorded |
| Production control | Incoming part checks, approved supplier list, line inspection and batch traceability | Ongoing compliance and corrective-action route | Production cannot silently diverge from the assessed model |
| Declaration and marking | Final product and label identity, available technical evidence | DoC content, legal references, conformity mark and signatory | Approved declaration and artwork are released together |
Exemptions Need Exact Scope
An exemption is not a blanket permission for a product category
Some specific technical applications can use a restricted substance above its maximum concentration while a valid exemption applies. The evidence must connect the exact substance, material, component, application and market date to the correct exemption text.
Great Britain operates an exemption system independent from the EU exemption system followed in Northern Ireland. A buyer planning both markets should check both current lists and determinations. Do not assume that a renewal, expiry or scope decision in one route automatically changes the other.
Each exemption decision should record its legal reference, permitted application, conditions, expiry or review date, affected parts and replacement plan. Reopen the technical review before the exemption changes, the component is redesigned or the product enters another territory.
Economic-Operator Duties
Private-label importing can transfer manufacturer obligations
Importer
The importer confirms the manufacturer completed the required work, keeps a copy of the declaration, ensures technical documentation is available and places its trade name and contactable address on the product or packaging.
Own brand
An importer placing EEE on the GB or NI market under its own name or trademark must meet the manufacturer's obligations. OEM artwork therefore changes more than the appearance of the color box.
Distributor
A distributor checks relevant markings and must not supply equipment it knows or has reason to believe is non-compliant. A compliance-affecting modification can transfer manufacturer obligations.
Ten-year evidence
Technical documentation and the declaration must remain available for ten years after the last product in the product line is first placed on the market. Supply-chain identification also requires long-term traceability.
Corrective action
Non-compliance, recalls and corrective measures need a controlled register. The responsible parties cooperate with OPSS and provide evidence when requested.
Evidence Failures to Stop Before Deposit
Reject documents that cannot be linked to the production SKU
| Weak evidence | Why it fails | Required correction |
|---|---|---|
| A one-page "RoHS certificate" with no material scope | It does not show the assessed model, material coverage, method, limits or production control. | Request the underlying declaration, report and technical evidence mapped to the actual SKU. |
| A report for a similar product or old supplier | Visual similarity does not prove identical materials, components or risk. | Document model-family differences and close every relevant gap before relying on shared evidence. |
| A supplier declaration with no part number | The buyer cannot connect the statement to the component used in production. | Add supplier, part, material, revision, date, signature and product application. |
| EU exemption used for GB without checking | GB exemptions are administered independently. | Verify the current GB exemption and keep a separate NI/EU decision where relevant. |
| Production component changed after testing | The supplied goods may no longer match the assessed sample or evidence set. | Apply written change approval, evidence review and testing where needed before shipment. |
Wholesale Project Workflow
Move from model selection to controlled UK RoHS production
Freeze territory and entities
Name the GB or NI manufacturer, importer, brand owner and distributor before selecting the declaration route.
Freeze product construction
Approve model, ratings, plug, function, accessories, BOM, materials, parts and suppliers.
Build the risk map
Identify high-risk homogeneous materials and match supplier declarations, test evidence and exemptions.
Close evidence gaps
Confirm sample identity, test plan, laboratory scope, results and production relevance.
Approve the technical file
Connect BOM, risk assessment, standards, reports, production controls and model identity.
Release declaration and artwork
Approve the territory-specific declaration, conformity marking, manufacturer and importer information.
Control production changes
Block unapproved material, component, supplier, color, coating and process substitutions.
Retain and respond
Keep the file and supply-chain records available for the required period and maintain a corrective-action route.
Current Official Sources
Verify the exact product and territory before market placement
This guide was reviewed against current official information on 29 July 2026. Buyers should verify the live legislation, exemptions and product-specific route with qualified UK professionals.
GOV.UK: Regulations - restriction of hazardous substances
GOV.UK: RoHS Regulations - Great Britain
Wholesale Project Intake
Send a model-specific UK RoHS evidence inquiry
Send the buyer company, target territory, manufacturer and importer, brand, exact product and model, quantity, ratings, plug, accessories, BOM status, available declarations and reports, requested exemption, destination port and target launch date.