EU RoHS electronic hazardous materials testing application guide for electronic
Date：2025-08-20 09:57:46 Classification
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The RoHS Directive is a mandatory standard established by EU legislation. It is the "Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment". The national RoHS certification is a requirement of the "Catalogue of Compliance with Standards for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products" issued by the State Administration for Market Regulation and the Ministry of Industry and Information Technology in 2019. A complete guide to EU RoHS hazardous substance testing for electronic toys, integrating the latest regulatory requirements and practical key points:
I. Core Scope of Application
1. Product Types Eligible for Compulsory Certification
- Electric toys: Products containing circuit boards, such as remote-controlled cars, electronic keyboards, light-up dolls, and intelligent robots
- Mixed-Material Toys:
- Plush toys with electronic components (e.g., talking teddy bears)
- Plastic toys with batteries (e.g., flashing tops)
- Electronic Learning Devices: Children's tablets, reading pens, and electronic building blocks
2. Exempt Products
- Pure plush/wooden toys without electronic functions
- Mechanical toys without circuits or batteries (e.g., wind-up toys)
II. Test Substances and Limit Requirements
| Hazardous Substances | Limits | Common Risk Areas
| Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr⁶⁺) | ≤0.1% | Solder joints, coatings, and metal parts
| Cadmium (Cd) | ≤0.01% | Batteries, switch contacts
| Polybrominated biphenyls (PBBs)/polybrominated diphenyl ethers (PBDEs) | ≤0.1% | Plastic casings, circuit boards
| Four new phthalates (DEHP/BBP/DBP/DIBP) | ≤0.1% | PVC materials, soft rubber accessories
Note: Starting July 2025, four new phthalate controls will apply to all electronic toys.
III. Certification Application Process
Step 1: Material Pre-inspection and Disassembly
- Disassembly Requirements:
- Classify toys by material (plastic, metal, circuit boards, wire, etc.)
- Coated parts require separate sampling (e.g., painted casings)
- Pretreatment: New samples must be ventilated for 48 hours to remove volatile odors
Step 2: Sample Submission for Testing
- Sample Quantity: ≥ 3 samples for the main material, with additional samples for high-risk components such as batteries
- Testing Time: 5-7 business days (extended to 10 days for complex products)
Step 3: Laboratory Selection
- Identify an EU Notified Body (e.g., Dezewei)
Step 4: Corrective Action and Reporting
- Common Issues:
- Excessive Lead (lead in solder) → Switch to lead-free solder
- Excessive Phthalates (PVC plasticizer) → Switch to TPE
- Report Content: Must include test data and conclusions for each substance tested
Step 5: Labeling and Documentation
- Mark the product or packaging with the CE+RoHS label after passing the test
- Supporting Documents:
- RoHS Declaration of Conformity (including manufacturer and importer information)
- Technical Documents (circuit diagram, materials list, test report)
IV. Cost Optimization Recommendations
1. Material Simplification:
- Reduce the number of plastics (each additional material incurs a 500 RMB testing fee)
- Prioritize certified raw materials (e.g., RoHS-compliant electronic components)
2. Scenarios for Mixed Testing:
- Parts of the same color and quality can be inspected together (e.g. multiple black ABS plastic parts)
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