Overview
RoHS (Restriction of Hazardous Substances) limits the use of certain hazardous substances in electrical and electronic equipment, so that products are safer to use and to recycle.
In India, RoHS requirements are part of the E-Waste (Management) Rules, 2022, notified by the Ministry of Environment, Forest and Climate Change (MoEFCC) and in force from 1 April 2023. The rules require producers of listed electrical and electronic equipment to ensure that new products do not exceed the prescribed limits for six substances, and give the Central Pollution Control Board (CPCB) powers to check compliance. The rules are available from MoEFCC and CPCB at https://cpcb.gov.in.
CE marking is the European Union’s declaration that a product meets all applicable EU legislation. For electrical and electronic products, this commonly means the Low Voltage Directive, the EMC Directive, the RoHS Directive and, for radio products, the Radio Equipment Directive. The manufacturer draws up a technical file, signs an EU Declaration of Conformity and affixes the CE mark. Some products need an EU Notified Body as well.
Note: Published commentary reports that the India RoHS exemption for imported spare parts ended on 1 April 2025, while specified equipment parts remain exempt for longer. Check the current rules and amendments for your product.
Who needs it
- Producers of electrical and electronic equipment sold in India, including manufacturers, importers and brand owners, for India RoHS.
- Exporters to the European Union for CE marking.
- Component suppliers whose customers ask for RoHS declarations and test data.
- E-commerce sellers, who are increasingly asked for compliance documents.
Products covered
India RoHS applies to the electrical and electronic equipment listed in the schedule to the E-Waste (Management) Rules, 2022, which is broad, covering IT and telecom equipment, consumer electronics, large and small household appliances, lighting, electrical and electronic tools, toys, medical devices and monitoring instruments, among others.
Restricted substances and limits under India RoHS:
| Substance | Maximum concentration (by weight, homogeneous material) |
|---|---|
| Lead (Pb) | 0.1% |
| Mercury (Hg) | 0.1% |
| Hexavalent chromium (Cr VI) | 0.1% |
| Polybrominated biphenyls (PBB) | 0.1% |
| Polybrominated diphenyl ethers (PBDE) | 0.1% |
| Cadmium (Cd) | 0.01% |
Documents required
For India RoHS:
- Bill of materials broken down to homogeneous materials
- Supplier declarations of conformity for components and materials
- Test reports for higher-risk parts (solders, plastics, coatings, cables), typically by XRF screening and wet-chemistry confirmation
- Records of any exemptions relied on
- RoHS compliance declaration in the product information booklet, where the rules call for it
- Data linked to your EPR registration
For CE marking:
- Product description, drawings and bill of materials
- Risk assessment
- Test reports to harmonised standards (safety, EMC, radio as applicable)
- RoHS evidence
- User instructions and labelling
- EU Declaration of Conformity
Process
- Scope. Identify whether the product is covered by India RoHS and which EU directives apply for CE.
- Data collection. Build the material breakdown and collect supplier declarations.
- Risk-based testing. Test parts where declarations are weak or the risk is high.
- Compile the technical file with evidence, exemptions used and the declaration.
- Declare and mark. Include the RoHS declaration in product information for India; sign the EU Declaration of Conformity and apply the CE mark for Europe.
- Maintain. Update the file when suppliers, materials or rules change.
Validity, renewal & surveillance
RoHS compliance is ongoing: it must hold for every unit you place on the market. Supplier changes and new exemptions or amendments can affect it. In India, CPCB may sample and test products and act against non-compliant ones. In the EU, market surveillance authorities can request the technical file and test products at any time.
How Aaditech helps
Aaditech is an NABCB-accredited Type A inspection body for electrical equipment (ISO/IEC 17020:2012), and our team is led by former Directors of the Bureau of Indian Standards. We understand how electrical products are built and where restricted substances tend to hide.
- Applicability review for India RoHS and the EU directives.
- Supplier declaration campaigns and gap analysis of your bill of materials.
- Lab coordination for XRF screening and confirmatory testing.
- Technical file and declaration preparation for India and the EU.
- Link-up with EPR registration, which draws on the same product data.
We are not an EU Notified Body; where one is needed, we help you prepare for it. Contact us for a RoHS review of your product range.
