We Had a RoHS Test Report, and Amazon Still Pulled Our Listing

RoHS & REACH Hazardous Substance Testing Guide

Hello, this is StartMade.

A brand selling home accessories on Amazon Europe had a small appliance factory in Bao'an (宝安), Shenzhen, make a USB-rechargeable LED mood lamp. It was a simple product: an ABS base, a silicone shade and a 1.5m PVC-jacketed USB cable in the box. The factory sent a CE Declaration of Conformity (DoC) along with a "RoHS certificate" bearing a lab's name, and the first 1,000 units sold without a problem. Four months later the brand reordered 3,000 units, and at pre-shipment inspection, brightness, charging, appearance and carton drop all passed.

About two months after the reorder went into FBA warehouses, an email arrived from Amazon. A German market surveillance authority had bought the lamp off the market, tested it, and found the plasticizer DEHP at 16% in the cable jacket. That is 160 times the 0.1% limit. The listing was deactivated at once, warehouse stock was frozen, and an additional shipment that had just landed in Hamburg was held at customs. Only then did the brand reread the "RoHS certificate." It was a test report issued two years earlier, and it covered just two parts: the ABS base and the silicone shade. The cable had never been tested, and on the reorder the factory had switched to a cheaper cable supplier.

Hazardous substances can't be seen, felt or caught by a function test. A cable 160 times over the limit bends and looks exactly like a compliant one. That is why products that pass every pre-shipment check blow up all at once at customs, in market surveillance or in a platform review. This post covers the difference between RoHS and REACH, why each part carries different risks, the limits of checks such as XRF and lab analysis, the gaps between test reports and actual materials, common supplier substitutions, and what to check in the spec sheet and at inspection.

"We have RoHS" and a single PDF test report are not enough. Write the applicable regulations, banned substances, and the material and supplier of every part into the spec sheet, check which parts the report actually tested, and test samples you pick yourself from production, part by part, to prevent customs holds and delisted products.

1. What "We Have a RoHS Certificate" Really Means

EU RoHS has no "certificate" issued by a government or official body. The manufacturer or importer declares conformity itself (the CE self-declaration) and keeps technical documentation and test reports as evidence. What a Chinese factory calls a "RoHS证书" is usually a lab test report (测试报告) or a one-page "statement of conformity" with a lab's logo on it. Whatever it is called, what matters is which parts of which sample were tested, and when.

People also mix up RoHS and REACH. Both are EU regulations and often mentioned together, but they differ in scope, substances and obligations.

If a product is electrical, you need to look at both RoHS and REACH; for non-electrical toys, bags and accessories, REACH (and toy safety rules for toys) takes center stage. Korea regulates children's products under its Common Safety Standards for Children's Products and the US under CPSIA, so different countries regulate similar substances with different numbers, and you need to settle the target market first. We covered certification by country in Episode 10 and children's products in Episode 65.

2. Even in One Product, Each Part Carries Different Risks

RoHS limits apply not to the weight of the whole product but to each homogeneous material. DEHP that is under 0.01% of the whole lamp can be 16% of the cable jacket alone. That is why testing has to be split by part and material, and why you need to know which part tends to contain what in order to pick the right samples.

As the table shows, the problem usually comes not from the main body but from "side" parts such as cables, paint, screws and rubber feet. Factories pay attention to the main resin but often buy sub-components from whoever is cheapest at the time. We covered metal alloy verification in Episode 162, lead and cadmium release from ceramic glazes in Episode 161, and recycled resin in Episode 125.

3. How to Check — From Reading Reports to Lab Analysis

Ask "有没有RoHS?" and the factory almost always answers "有，都符合" (yes, it all complies). But having a test report does not guarantee that what is being made now meets the limits.

Read a Test Report in This Order

Start by checking that the sample name and model match your product. A vague name like "LED lamp" or a different model number makes it hard to call it your product's report. Next comes the list of tested parts. A proper report numbers each part with a photo, written like "1. white plastic housing, 2. black PVC jacket…". Compare that list line by line against your BOM and missing parts jump out. Then check whether the test items are the 6 RoHS substances or all 10 (whether the 4 phthalates are included), when it was issued, and whether the applicant (申请方) is your factory or a raw material supplier. Checking that the lab is ISO/IEC 17025 accredited and that the report number can be looked up on the lab's website also catches forged reports.

XRF Is a Screening Tool, Nothing More

The handheld XRF is the most common tool in the field. Results come in tens of seconds and the sample isn't destroyed, which makes it a good fit for pre-shipment inspection. But XRF only sees elements. If it finds chromium, it can't tell harmless trivalent from hexavalent; if it finds bromine, it can't tell PBDE from other flame retardants. Phthalates are organic compounds of carbon, hydrogen and oxygen, so it doesn't pick them up at all. Thin plating and small parts get read together with the material underneath and produce false positives, while trace amounts can be missed. Use XRF as a first screen that separates "clearly passes" from "send to the lab," and send parts with readings near the limit, or parts where phthalates are a concern, for lab analysis.

4. What Are the Limits?

Here are approximate criteria commonly referenced in practice. Regulations change often and have many exemptions, so confirm the criteria that actually apply with a lab.

When you set criteria, writing a scope such as "EU RoHS 10 substances, REACH Annex XVII and the latest SVHC list" holds up better in a dispute than a single line saying "RoHS compliant." For importing electrical products in general, see Episode 75 as well.

5. Gaps Between Test Reports and Actual Materials

Ask for a test report and the factory usually sends a PDF or two right away. The documents themselves are rarely fake. They just aren't connected to what is being made now.

6. Common Supplier Substitutions

Hazardous substances don't show in looks or function at all. Materials of the same color and feel can be bought far cheaper, so when cost pressure comes, factories change the sub-components and materials no one notices first. Here are the types we have actually run into in consultations.

The most common pattern is switching the supplier of sub-components such as cables or accessories on a reorder. The finished-goods factory says "我们自己的料没变" (our own materials haven't changed), and that may not actually be a lie. What changed is the parts it buys in. We covered procedures requiring prior approval for material and part changes in Episode 119, and conductor quality in power cords in Episode 152.

7. The Damage When Limits Are Exceeded

Hazardous substance problems surface after sale, at customs, in market surveillance or in platform reviews. A problem in one part spreads to every unit from the same period, and the damage far exceeds the product's price.

• Customs holds and destruction: Goods are tied up while customs or market surveillance takes and tests samples, and a failure adds return or destruction costs.
• Platform delisting: Platforms like Amazon take listings down first once notified, and FBA stock sits frozen while storage fees keep running. Relisting requires new reports and corrective action records.
• Recalls and public alerts: The EU publishes dangerous products on Safety Gate, so the brand name stays in search results for a long time.
• Customer claims: If you supplied retailers or B2B customers, expect demands for recall costs and penalties.

See Episode 53 for recalls and product liability, Episode 16 for Amazon FBA sourcing, and Episode 36 for claims and dispute handling.

8. Items to Put in the Spec Sheet

One line saying "符合RoHS" means different things at different factories. Put the items below into a table and attach it to your spec sheet.

Of these, the part-by-part material list does the most. Once parts and suppliers are written down, changing a sub-component without approval is itself a breach of contract. See Episode 59 for writing spec sheets and BOMs.

9. How to Add Hazardous Substance Checks to Your QC Checklist

Sample Stage

At the sample stage, set your baseline. Get one extra unit made to the same spec as the approved sample, run XRF on each part, and send parts where phthalates are a concern, such as cable jackets and soft plastics, for lab testing. Record the results with photos, materials and suppliers for each part, and seal the approved sample with the date and item number. Sample management is covered in Episode 34.

Production Stage

On the day materials and parts arrive at the factory, get photos of delivery notes, labels and supplier names. Checking cable reel labels, paint can product codes and the actual solder on the workbench quickly shows whether a supplier has changed. See Episode 102 for production tracking.

Pre-Shipment Inspection Stage

The inspector picks packed products personally, runs XRF on each part and compares the readings with the sample-stage records. They also look for signs that change along with a supplier, such as cable printing, connector shape and screw color. If readings come in near a limit or a part looks different, seal random samples and send them to a third-party lab for part-by-part testing. Pre-shipment inspection is covered in Episode 100.

10. Example Request Wording for the Factory

Putting the wording below into your purchase order or spec sheet takes the choice of materials and parts out of the factory's hands and makes it easier to assign responsibility if something goes wrong.

"本产品所有均质材料须符合欧盟RoHS指令（2011/65/EU及(EU) 2015/863，10项物质）、REACH法规附件XVII及下单时最新SVHC候选清单要求。供应商须提交零部件材料对照表，列明每个部件的材质、颜色、供应商及对应检测报告编号。禁止使用DEHP等邻苯二甲酸酯类增塑剂、有铅焊锡、六价铬钝化、含铅或含镉颜料及未经确认的再生料。如需更改原料、零部件、供应商、油漆或电镀工艺，须提前书面确认并提供新的检测报告。检测报告须由具备ISO/IEC 17025资质的检测机构出具，注明本产品型号并附各测试部位照片，出具日期在12个月以内。出货前由我方从成品中随机抽样，按部件封样送第三方检测机构检测，如不合格，整批返工或退货，检测、物流及平台损失费用由供应商承担。"

11. Three Real Cases

These are anonymized versions of patterns we often see in consultations. Amounts and figures are examples.

Case 1 — USB-Rechargeable LED Mood Lamp

This is the case from the start of this post. The factory first insisted that "the cable is an outsourced part, so it's not our responsibility." Because the purchase order said only "RoHS compliant" and set no part list or suppliers, it was hard to treat the cable supplier change itself as a breach of contract. In the end the two sides split the cost of reworking with phthalate-free cables, and it took almost three months to get the listing back up.

Case 2 — Children's Hair Clip and Bracelet Set

A company importing children's hair clips and bracelets with zinc alloy charms from Yiwu (义乌) added XRF to its pre-shipment inspection. The main charms were fine, but the small jump rings linking the bracelet chain showed cadmium at around 0.3%. Lab analysis also came in over the limit, so the company stopped the shipment and had the rings remade by a different supplier. Since then, it has the factory list jump rings and clasps as separate lines in the part matrix.

Case 3 — A Children's Raincoat Cleared on XRF Alone

A seller of PVC children's raincoats checked lead and cadmium with XRF before shipment, found none and passed the lot. A few months into sales, a market surveillance test found DEHP and DINP far over the limit in the raincoat fabric. Phthalates are invisible to XRF. Leaving lab GC-MS testing out for a soft PVC product was the root of the problem.

12. Common Mistakes

The most common is ending the check once the factory sends a "RoHS certificate." Without reading which parts were tested and when, you won't notice that the cable or paint is missing. Looking only at RoHS and skipping REACH is risky, and so is assuming a non-electrical product needs no attention because RoHS doesn't apply. We also often see people trust that phthalates are fine because XRF said "not detected," or calculate limits against the weight of the whole product. The one that causes the biggest problems later is assuming a reorder matches the first lot that passed, and never checking for sub-component supplier changes.

13. Hazardous Substance Control Checklist

Sample Stage

• Wrote the applicable regulations (RoHS, REACH, SVHC, etc.) for the market and product category into the spec sheet
• Received a part matrix of materials, colors, suppliers and report numbers
• Compared each report's sample name, tested parts, test items, issue date and lab against the BOM
• Looked up report numbers on the lab's website
• Ran XRF on each part of the approved sample and sent soft PVC and rubber for lab testing

Production Stage

• Received photos of delivery notes, labels and supplier names for incoming materials and parts
• Checked cable reels, paint product codes and the actual solder at workstations
• Applied material, part or supplier change requests only after written approval and a new report

Pre-Shipment Inspection Stage

• Ran XRF on each part of randomly picked finished goods and compared with sample records
• Checked for signs of changed parts such as cable printing, connector shape and screw color
• Sealed and sent to a lab the parts where phthalates are a concern and parts with readings near a limit

Wrap-Up - Check the Tested Parts, Not the Name on the Report

A product leaving the factory looks and works the same whether its cable jacket holds 16% DEHP or none at all. The difference surfaces months later at customs, in market surveillance or in a platform review, and by then the whole shipment is already in warehouses and customers' homes. Writing part materials and suppliers into the spec sheet, comparing the tested parts in reports against the BOM, and testing samples pulled from production costs far less than the customs holds, delistings and recalls you would pay for later.

There is also something you can do right now. Ask the factory currently in production for a matrix of materials, suppliers and report numbers by part, along with every original test report it holds. If the only answer is "都有RoHS，放心" (it all has RoHS, don't worry), build a hazardous substance control sheet and send it before your next order.

StartMade supports you on the ground with spec sheets that set applicable regulations and part-by-part material lists, review and verification of supplier test reports, checks of incoming materials and parts during production, and pre-shipment inspection including XRF screening and sealed samples. If you have already faced a customs hold or a delisting, we start by analyzing the remaining stock; if you are preparing a new product, we start with the spec sheet together.