What is in the files
- the technical documentation of each product: the ten restricted substances of Annex II with their maximum concentrations and a column for your evidence, the exemptions you rely on, your supplier declarations and test reports, and the six elements of Module A;
- the EU declaration of conformity (Annex VI) in each language you choose, in the wording published in the Official Journal in that language;
- the REACH Article 33 information for your customers, written from your answer: none above 0,1 %, or the substances and the information for safe use;
- a read-me with what the kit leaves out.
The ten substances
Lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE) and the four phthalates DEHP, BBP, DBP and DIBP: 0,1 % by weight in homogeneous materials. Cadmium: 0,01 %. The phthalates were added by Delegated Directive (EU) 2015/863 and apply to medical devices and monitoring and control instruments (categories 8 and 9) from 22 July 2021. Annexes III and IV list exemptions, many with an expiry date; Annex IV applies only to categories 8 and 9.
Who must do what
The manufacturer draws up the documents and keeps them for 10 years after the product is placed on the market (Article 7). An importer checks that the manufacturer has done so and keeps a copy of the declaration for 10 years (Article 9). The declaration is translated into the language or languages required by the Member State where the product is sold (Article 13). The harmonised standard EN IEC 63000:2018 describes how to build the technical documentation from supplier and material information; the kit leaves the standards for you to name.
What the kit does not do
It does not test your product or judge whether an exemption covers your use. The category, exemptions, evidence and REACH answer are yours; whatever you leave empty is marked TO COMPLETE. The kit never writes that a substance is below its limit. It does not check the Candidate List for you, notify the SCIP database, or cover REACH restrictions, WEEE registration or other directives such as electrical safety.
For a REACH declaration on its own, also for products outside RoHS, use the free REACH SVHC declaration generator.
Nothing you type leaves your browser; the files are built on your device. Templates, not legal advice. The declarations quote the Official Journal; everything you type stays as you typed it and is not translated. The other files are in English.
Sources
- Directive 2011/65/EU (RoHS), Articles 4, 7, 9, 13 and 16 and Annexes I, II, III, IV and VI
- Consolidated text of 1 July 2026, with the amendments to Annexes II, III and IV
- Regulation (EC) No 1907/2006 (REACH), Article 33, consolidated text of 22 June 2026
- Decision No 768/2008/EC, Annex II, Module A (internal production control)