RoHS and REACH SVHC Compliance for Kitchen Appliances
RoHS restricts ten hazardous substances, including lead, mercury, cadmium and four phthalates, in electrical appliances sold in the EU. REACH adds duties for substances of very high concern: if an article contains an SVHC above 0.1 percent by weight, the supply chain must be informed and the article must be notified to the SCIP database. Both regimes run on supplier declarations, so the chemical file is assembled, not invented.
Two regimes, one chemical file
RoHS and REACH are often mentioned in the same breath, but they do different jobs. RoHS is a fixed restriction list: ten substances, concentration caps in homogeneous materials, no exceptions except published exemptions. REACH is a dynamic system: the Candidate List of substances of very high concern grows through the year, and the duties attach to presence above a threshold rather than a fixed prohibition. A compliant appliance satisfies both, and the technical file that proves it is assembled from supplier declarations plus targeted testing.
For a factory, the assembly is the work. The chemistry itself is decided by material choices made long before the file is written, which is why component sourcing discipline matters more than laboratory volume.
What the RoHS file contains
| Element | Who provides | Notes |
|---|---|---|
| RoHS declaration per part or material group | Component suppliers | Must name the part, not just the company |
| High-risk part test report | Laboratory | Cords, cable jackets, coatings, solder |
| Risk assessment per EN IEC 63000 | Factory or lab | Justifies what was tested and what was not |
| Declaration of conformity | Manufacturer or importer | Signed by the EU-facing entity |
The risk-based approach is the part buyers question most. A factory that tested everything once in 2021 and reuses the report for a 2027 model has a gap, not a file. A factory that can show the assessment logic, the tested parts and the declaration dates per model passes the same audit in minutes.
What the REACH file adds
The SVHC duty is presence-based. Above 0.1 percent by weight in an article, communication flows down the supply chain and notification to the SCIP database flows up from the EU-facing entity. Below the threshold, no duty, but the result must be evidenced. Because the Candidate List updates several times a year, the file carries a check date and the list version it was checked against.
Two practical implications. First, declarations must be checked against the current list, not against the list from when the declaration was issued, which is why old declarations expire in effect even if they look valid. Second, an article-level screen differs from a material test: an SVHC can be present in a coating at a concentration that matters even when the bulk plastic is clean.
Where kitchen appliances actually fail
Cord jackets and flexible gaskets dominate the RoHS failure list because of phthalates. Paints and printed markings occasionally carry restricted pigments. Solder is a solved problem for responsible manufacturers but worth declaring, because hand repairs and rework can reintroduce lead. Food-contact parts are a separate regime, but the same part often carries both a food-contact declaration and a chemical declaration, so the paperwork flows together through one supplier form.
What buyers ask at qualification
Buyers ask for the declaration set, the test report for high-risk parts and the date the file was last checked against the Candidate List. They also ask what happens when a supplier changes, and the answer should be a process: re-declaration before the first shipment with the new part. Factories that answer with a named process and a sample document pass faster than factories that answer with confidence alone.
How this connects to the rest of the file
Chemical compliance sits inside the broader EU conformity described in our air fryer certification guide and the cross-market comparison of CE, UL, ETL, GS and UKCA. The food-contact declarations are covered separately in our food contact materials guide, and the EU market duties are summarised on the EU market page.
How exemptions work, and why they matter to designs
RoHS carries a system of exemptions: specific applications where a restricted substance remains permitted until alternatives mature, each with an expiry or review date. Exemptions apply to defined uses, not to products, and using one requires citing it in the documentation. For kitchen appliances the exemptions matter mostly in legacy component categories rather than in the main appliance design, but a component supplier may rely on one for a specific part, and the file should say so.
The buyer-facing consequence is transparency. A declaration that says which parts rely on which exemption, with the expiry dates, is a usable document; a bare pass-fail declaration hides the schedule that the buyer’s own compliance team must track. When the exemption expires, the component needs a redesign or a substitution, and the factory that tracks expiry dates flags it before the buyer’s audit finds it.
What auditors actually read
Chemical files are audited by reading, and the documents that survive are the ones a stranger can follow. The audit trail that works: a cover sheet per model listing the documents in the file with dates; declarations that name parts and reference the current list version; test reports tied to specific samples and parts; and a change log showing what was re-declared when a supplier changed. None of this is sophisticated, and together it turns a folder of PDFs into evidence.
The failures auditors find are just as unsophisticated: a declaration from a supplier who has since been replaced, a test report for a model that no longer ships, a list version two years old. The fix is administrative, which is good news, because administrative fixes cost an afternoon. Factories that assign the file to a named owner with a quarterly review pass audits without drama, and the audit result becomes a sales asset when buyers ask for references.
The UK angle in practice
The UK retained its own chemical regimes after the transition, and the divergence that matters for exporters is procedural rather than chemical today. The substance lists are maintained separately, so a file built for the EU must be checked against the UK lists for a UK launch, and the UK enforcement framework acts on its own register. In day-to-day sourcing the practical question is who runs the check: the buyer’s compliance team usually owns it, and the factory’s declarations feed it.
A declaration set that states the list version and date serves both regimes, because the same documents are checked against two lists. The pattern that fails is a declaration that names neither, which forces the buyer to re-obtain documents per regime. Factories that structure their declarations once, with the metadata both teams need, serve both markets with one document set, and that efficiency is visible in the qualification process.
The sourcing translation of this guide is short. Ask for the declaration set and the test report for the high-risk parts, and check that the documents name the parts. Ask when the file was last checked against the Candidate List, and expect a date rather than a yes. Ask what happens when a component supplier changes, and expect a named process. The three answers separate factories with a chemical compliance process from factories with a folder.
The market-level consequence follows the same logic. Border rejections and marketplace takedowns for chemical reasons are rare for suppliers with current files and common for suppliers with old ones, because the enforcement targets the weak paperwork first. The cost asymmetry means the declarations are best treated as shipping documents: part of the order pack, refreshed per revision, archived with the model number.
A practical checklist
- Collect RoHS and SVHC declarations per component, referencing part numbers.
- Test the high-risk parts: cords, jackets, coatings, solder.
- Record the assessment logic per EN IEC 63000 in the technical file.
- Check declarations against the current Candidate List quarterly, and log the date.
- File SCIP notifications only when a threshold is exceeded, and keep the clean results too.
- Re-issue declarations whenever a component supplier changes, before the first shipment.
Frequently asked questions
What does RoHS restrict in a kitchen appliance?
RoHS caps the concentration of ten substances in the homogeneous materials of the appliance: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers, and the four phthalates added by the 2015 amendment. The caps apply per material, not per product, which is why laboratories test individual parts. Most compliance failures in kitchen appliances come from cords, cable jackets, paints and solder, so those parts deserve the closest declarations.
Is RoHS testing mandatory?
RoHS conformity is demonstrated through the manufacturer's technical documentation, and a test report from a laboratory is the normal support. The EU recognises the assessment approach in the EN IEC 63000 standard, which allows risk-based evaluation: high-risk materials get tested, low-risk parts rely on declarations. A full-scope laboratory screen of every part is rarely necessary, but a screen of the high-risk parts plus complete supplier declarations is the standard file.
What are SVHCs and why do they matter?
Substances of very high concern are chemicals identified by the European Chemicals Agency under REACH, and the Candidate List grows as new substances are added. If an article contains an SVHC above 0.1 percent by weight, the supplier must inform their customers, and any EU producer placing the article on the market must notify the SCIP database. The list changes several times a year, so the chemical file needs a re-check date, not just a one-time pass.
What is the SCIP database?
SCIP is the EU database where articles containing SVHCs above the threshold are notified before they are placed on the market. The notification identifies the article, the substance and its concentration range. Importers and brand owners file it, not the factory outside the EU. If your declarations show no SVHCs above the threshold, no notification is needed, and the clean result itself becomes part of the file.
What declarations should the factory collect?
A RoHS declaration per material group, a REACH SVHC declaration against the current Candidate List, and declarations from the component suppliers for cords, cables, coatings and plastics. The declarations must reference the specific parts and model numbers, because a generic company-level statement does not survive an audit. When a component changes supplier, the declaration needs re-issuing, which is why the file tracks component revisions.
Do phthalates still cause problems?
Yes, mostly in flexible parts. The four restricted phthalates were widely used as plasticisers in cable jackets, gaskets and soft-touch coatings. Modern materials avoid them, but old stock, cheap substitute compounds and unverified suppliers keep the failures coming. Testing the flexible parts of every new model is the cheap insurance, and a failure found in testing costs a fraction of a recall or a border rejection.
Does the UK differ from the EU?
The UK retained RoHS and REACH frameworks after leaving the EU, with its own enforcement and its own additions to the restricted or candidate lists over time. In practice the substance lists are close, but they are maintained separately, so a declaration set for the EU must be checked against the UK lists for a UK launch. Buyers selling into both markets ask for both checks in one request.
How often should the chemical file be refreshed?
At minimum, whenever the Candidate List is updated, whenever a component or material supplier changes, and when a model is redesigned. A practical discipline is a quarterly review of the declarations against the current list, logged with a date and the reviewer. Buyers in the EU increasingly ask for the review date in the supplier qualification pack, because a file without dates cannot be audited.