Direct answer: A material declaration is not a test report, and most of the ones circulating in lighting RFQs prove almost nothing. RoHS restricts ten substances at fixed limits inside the luminaire. REACH reaches whatever the SVHC candidate list touches – 253 entries as of the February 2026 update – through information duties rather than bans. Prop 65 requires a warning, not a reformulation, for products sold in California. A defensible file names the substances, the thresholds, the documents behind them and the dates those documents were issued.
Buyers rarely push back on this paperwork until an audit, a marketplace takedown or a customer questionnaire exposes it. By then the container has landed. Here is what each of the three regimes actually demands, and how to tell a declaration that carries weight from one that is filler.
What RoHS actually restricts – and where luminaires sit
The RoHS Directive 2011/65/EU restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and the four phthalates DEHP, BBP, DBP and DIBP added by the 2015/863 amendment. The limits are per homogeneous material: 0.1% by weight for each substance except cadmium, which sits at 0.01%. The phthalate limits have applied since 22 July 2019, the same date the open scope took effect and brought cables and spare parts fully into the Directive.
That last point matters for lighting. A luminaire was always in scope, but the PVC flexible cord feeding it only became fully covered on that date – and flexible cable insulation is, by a wide margin, the most likely place for a phthalate exceedance in an LED fitting. Gaskets, rubber seals, paint films and printed markings come next. The LED board itself almost never fails.
RoHS compliance is declared, not certified. There is no RoHS certificate issued by any authority; the producer compiles technical documentation and issues a declaration of conformity. EN IEC 63000:2018 is the harmonised standard describing how to assess and document restricted substances, and it replaced the older EN 50581. If a supplier hands you a one-page “RoHS certificate” from a laboratory, that document may support one batch of one component – it is not the compliance file. For how the declaration sits in the wider EU paperwork set, see our guide to the CE marking and Declaration of Conformity for LED luminaires.
The phthalates hide in the cable, not the PCB
DEHP and its relatives are plasticisers. They make PVC soft, which is why flexible cords, cable sheaths, grommets and soft-touch coatings are the risk points. When a shipment is stopped at an EU border for phthalate screening, it is usually the cord that fails, at 0.3% or 0.5% DEHP in the insulation.
The practical control is boring: get a material statement per cable and per gasket part number, not a blanket “phthalate-free” line in a quotation. Blanket statements are unverifiable and, in an audit, worse than saying nothing, because they show the producer did not look.
REACH is a moving target: the SVHC list is now 253 entries
REACH, Regulation (EC) No 1907/2006, works differently from RoHS. Instead of fixed bans, the European Chemicals Agency maintains a candidate list of substances of very high concern – SVHCs – and the list grows. ECHA added n-hexane and bisphenol AF and its salts on 4 February 2026, taking the list to 253 entries, and producers of articles containing the new substances above thresholds have until 4 August 2026 to notify.
Three duties attach, and none of them is optional:
- Article 33 communication. If an article contains an SVHC above 0.1% by weight, the supplier must pass enough information downstream to allow safe use – at minimum the substance name. A consumer who asks in writing must receive an answer within 45 days, free of charge.
- Article 7(2) notification. If the substance is above 0.1% in the article and exceeds one tonne per producer per year, ECHA must be notified within six months of the substance being listed.
- SCIP database. Under the Waste Framework Directive, articles containing SVHCs above 0.1% must be reported to ECHA’s SCIP database – in force since 5 January 2021 – so that waste operators can identify them at end of life.
For a luminaire maker this turns compliance into a routine: every time the list grows, re-screen the bill of materials for the new entries. Reports that test only the original 2011 substance list are outdated the moment a new SVHC lands, which is why European buyers increasingly ask for the list version your screening referenced. A declaration that does not state a candidate-list date answers a question that was out of date before you read it.
Prop 65: the short-form warning changed on 1 January 2025
California’s Proposition 65 is a different animal: it regulates warnings, not composition. The list of chemicals – maintained by OEHHA – holds more than 900 entries and is updated at least annually. If a product exposes a person to a listed chemical above a safe-harbor level, the product needs a clear and reasonable warning, and the civil penalty runs up to USD 2,500 per violation per day, which private enforcers multiply across SKUs and sales channels.
The 2025 amendments – approved by OAL on 26 November 2024 and effective 1 January 2025 – changed the short-form warning. It must now name at least one listed chemical for each applicable endpoint, cancer or reproductive harm, instead of the old generic sentence. Businesses may use “WARNING”, “CA WARNING” or “CALIFORNIA WARNING”, the minimum type size is 6 point, and the new content is enforced from 1 January 2028; products manufactured and labelled before that date may sell through with the old short-form. Online sales need the warning on the product display page or a clearly marked hyperlink to it.
For lighting exporters the exposure is the same cast of characters: lead in solder or brass, phthalates in cords and gaskets. The options are the same too – reformulate, test down to a safe-harbor level, or label. What you cannot do since 2025 is copy a generic short-form onto the carton and assume it will hold.
Three regimes, three different obligations
| RoHS (EU) | REACH SVHC (EU) | Prop 65 (California) | |
|---|---|---|---|
| Nature | Restriction – substances banned above limits | Information duty – disclose above 0.1% w/w | Warning duty – label above safe-harbor levels |
| Threshold | 0.1% per homogeneous material (cadmium 0.01%) | 0.1% per article by weight | No significant risk / maximum allowable dose levels per chemical |
| List | Ten substances, fixed | 253 SVHC entries as of 4 February 2026, growing | 900+ listed chemicals, updated at least annually |
| Output | Declaration of conformity + technical file (EN IEC 63000:2018) | Downstream information, ECHA notification, SCIP entry | On-product and online warning text |
| Key dates | Phthalates since 22 July 2019 | New entries: notify by 4 August 2026 | New short-form enforced from 1 January 2028 |
Because the three regimes ask different questions, one document cannot answer all of them. The failure pattern we see in incoming supplier files is a single “environmental compliance certificate” offered as if it covered RoHS, REACH and Prop 65 at once. It covers none of them well.
How to read a declaration that proves nothing
Most useless declarations share the same defects. Use this as a triage list when a new supplier’s paperwork lands:
| Red flag | What it usually means | What to request instead |
|---|---|---|
| “RoHS compliant” with no date and no list version | Template reused for years, substances added in 2015 never screened | Declaration naming 2011/65/EU as amended by (EU) 2015/863, signed and dated |
| No homogeneous-material basis stated | Testing was done at part level, not at material level, so limits cannot be judged | Test reports per material, with the limit basis stated |
| “Does not contain SVHC” with no candidate-list date | Screened against a list that has since grown | Statement referencing the candidate list version and date |
| Certificate instead of declaration for RoHS | Producer misunderstands the regime; no technical file exists | Technical documentation per EN IEC 63000:2018 plus a signed DoC |
| Prop 65 generic short-form without a chemical name | Label predates the 2025 amendments | Label review against the new content rules before 1 January 2028 |
Building a file that survives an audit
A defensible material file for a lighting range has four layers, and every one of them is cheap to maintain while the product is in production:
- Full material disclosure per component. Cable, gasket, paint, solder, connector, driver housing – each with a supplier declaration naming the substance basis.
- Screening against the current lists. RoHS’s ten substances, the SVHC candidate list with its date, and the Prop 65 list as of the shipment date.
- SCIP records where required. If any article exceeds 0.1% for an SVHC and you are the EU producer, the SCIP submission number belongs in the file too.
- A dated declaration, signed by the legal entity that places the product on the market. Not the factory, not the trader – the producer of record.
None of this is glamorous, and that is the point. European and California enforcement both target the gap between what a product’s paperwork claims and what its bill of materials contains. The suppliers who keep the four layers current treat each SVHC update and each label change as a small routine task; the ones who do not meet the cost all at once, in a stopped container or a 60-day cure letter. For the laboratory work that sits under EU market access more broadly, our overview of EMC and LVD testing for LED luminaire importers covers the safety side of the same file.
Frequently asked questions
Does an LED luminaire need laboratory RoHS testing to be sold in the EU?
No test is legally mandated – RoHS is a self-declaration regime backed by a technical file. In practice, producers build the file from supplier declarations plus targeted testing of high-risk materials such as PVC cords, paints and solders. A full-bill-of-materials third-party test is one way to build evidence, not the only way.
Is Prop 65 relevant if I sell only to distributors, not consumers?
Yes. The warning duty attaches to exposures from product use in California, and business-to-business sales do not exempt the product where end users are employees or consumers. Warning requirements and wording differ slightly for occupational exposure contexts, so labels and placement should be reviewed against the regulation rather than copied from a consumer template.
How often should material declarations be refreshed?
Re-screen whenever the SVHC candidate list grows – it was updated on 4 February 2026, for example – and at least annually for Prop 65, whose list is revised at least yearly. A declaration with no list date should be treated as expired on arrival.
Who files the SCIP notification – the factory or the EU importer?
Whoever is the producer placing the article on the EU market: typically the EU importer or, for direct sales, the non-EU seller through its authorised setup. The factory cannot hold the obligation because SCIP entries are tied to the entity placing goods on the EU market, not the manufacturing site.
What single question filters a weak supplier fastest?
Ask for the candidate-list version date referenced in their latest REACH screening. Suppliers with a real process answer with a date in seconds; suppliers with a template answer with another template.
This article is a procurement guide, not legal advice. Confirm requirements for your specific product and market with a qualified compliance provider.
