RoHS Certification and Compliance in India
If you make, import or brand electrical and electronic equipment, Rule 16 of the E-Waste (Management) Rules, 2022 caps six hazardous substances in your products. We line up the lab testing, technical file and RoHS self-declaration for India, and explain what changes when you export to Europe under CE RoHS.
What it is
RoHS stands for Reduction of Hazardous Substances. In India, it is a set of limits on six substances in new electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). There is no single government “RoHS certificate”. What you hold instead is proof: lab test reports, a technical file and a self-declaration that your products meet the limits.
The rule is Rule 16(1) of the E-Waste (Management) Rules, 2022, notified as G.S.R. 801(E) and in force since 1 April 2023. It applies to producers of the equipment listed in Schedule I of the Rules, which runs to 106 items. The Central Pollution Control Board (CPCB) administers the Rules through its EPR portal for e-waste, where a producer’s registration includes the RoHS self-declaration.
Who it applies to
You make electronics for India
Makers of equipment listed in Schedule I, from IT and telecom gear to consumer electronics and household appliances, and their components, consumables, parts and spares.
You import or sell under your brand
Under the Rules, a producer includes anyone who sells equipment under its own brand or imports it. If your name is on the product or the bill of entry, the limits are your responsibility.
You ship to Europe
Products sold in the European Union must meet the EU RoHS Directive, which restricts ten substances and requires CE marking. Here is the catch: India-only compliance does not cover the four extra substances.
Why it matters
EPR registration needs it
Producer registration on the CPCB portal asks for a RoHS self-declaration and a declaration that the technical documents exist. No declaration, no registration.
Customers can check your claim
When a buyer asks for RoHS evidence, you send the test report and declaration you already hold. No fresh testing for each enquiry.
One file can serve two markets
A product tested against the EU’s ten-substance list also covers India’s six. Planning the testing once saves money if you export.
India RoHS vs CE RoHS
| India RoHS | EU (CE) RoHS | |
|---|---|---|
| Law | Rule 16, E-Waste (Management) Rules, 2022 | Directive 2011/65/EU, as amended by Delegated Directive (EU) 2015/863 |
| Substances | Six: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE | Ten: the same six plus four phthalates (DEHP, BBP, DBP, DIBP) |
| Limits | 0.1% by weight in homogeneous materials; cadmium 0.01% | 0.1%; cadmium 0.01% |
| Scope | Equipment listed in Schedule I (106 items) | All products with an electrical or electronic component, unless excluded |
| Proof | Self-declaration and technical documents (EN 50581 / EN IEC 63000) on the CPCB portal | EU declaration of conformity and CE marking |
“Homogeneous material”, as the EU Directive defines it, means a material that cannot be split mechanically into different materials, such as the plastic of a cable sheath or the solder on a joint. The limit applies to each such material, not to the product’s total weight. That is why one lead-bearing solder joint can fail a product that is 99% plastic and metal.
Picture a Faridabad unit that makes LED drivers for Indian brands and has just landed its first order from Germany. Its India file covers six substances. For the German buyer it must also show the four phthalates are within limits, which mostly means checking soft plastics such as PVC cable sheaths, and the product must carry CE marking with an EU declaration of conformity.
Documents required
Company papers
- PAN, GST registration and certificate of incorporation
- Import Export Code, for importers and exporters
- Authorisation for the signatory
Product papers
- Bill of materials, listing each part and material
- Supplier declarations and test reports for components
- Product drawings or photographs
Compliance papers
- Test reports from an accredited laboratory
- Technical documentation as per EN IEC 63000
- Signed RoHS self-declaration
How it works
Check whether your product is covered
We match your product against Schedule I, check whether any Schedule II exemption applies and ask where you sell. Say a Delhi trader imports Bluetooth speakers under its own brand: that is consumer electronics, so the trader is the producer and signs the declaration.
Chase your suppliers for data
We build the bill of materials with you and gather declarations and reports from your component suppliers.
Test the risky parts
Parts without reliable supplier data go to an accredited laboratory for testing. The lab does the analysis; we coordinate samples and reports.
Build the technical file
We assemble the technical documentation in the EN IEC 63000 format and draft the self-declaration for your signature.
File it and keep it current
The declaration goes into your producer registration on the CPCB EPR portal. In practice, the file goes stale when a supplier changes, so we update it whenever your bill of materials does.
Timelines
Comply before the first sale
Rule 16 limits apply to new equipment, so compliance must be in place before the product is sold or imported.
Schedule II C equipment: exemption over, spares until 2028
The Second Amendment Rules of 24 July 2023 exempted Schedule II C equipment until 1 April 2025, so new units must now comply. Their parts and spares stay exempt until 1 April 2028 where compliant alternatives are not available.
Components for pre-2014 Schedule II B equipment
Components for Schedule II B equipment placed on the market before 1 May 2014 are exempt where compliant alternatives are not available.
What happens if your products do not comply
Environmental compensation
Rule 22 of the E-Waste Rules lets CPCB levy environmental compensation for violations of the Rules.
Penalty under the EP Act
The Rules are made under the Environment (Protection) Act, 1986. Section 15 provides a penalty from ₹10,000 up to ₹15 lakh, plus up to ₹10,000 a day for continuing failure.
Registration problems
A false self-declaration puts your producer registration at risk, and without registration you cannot lawfully sell covered equipment.
Frequently asked questions
Is there a government-issued RoHS certificate in India?
No. India RoHS works on self-declaration backed by evidence. Under Rule 16 of the E-Waste (Management) Rules, 2022, the producer declares that its equipment meets the limits and keeps the technical documents to prove it. The “RoHS certificate” many buyers ask for is usually an accredited lab’s test report or a compliance certificate from a testing body. With a proper file, you can answer either request quickly.
What are the India RoHS limits?
0.1% by weight in homogeneous materials for lead, mercury, hexavalent chromium, PBB and PBDE, and 0.01% for cadmium. These come from Rule 16(1) of the E-Waste (Management) Rules, 2022. The limit applies to each homogeneous material, such as a solder joint or a plastic casing, not to the whole product. Testing the right parts, rather than the whole unit, keeps costs sensible.
How is CE RoHS different from India RoHS?
CE RoHS restricts ten substances; India restricts six. The EU Directive 2011/65/EU, amended by Delegated Directive (EU) 2015/863, adds four phthalates: DEHP, BBP, DBP and DIBP, restricted from 22 July 2019. The EU also requires a declaration of conformity and CE marking. A product that passes the EU list also meets India’s six-substance limits, so exporters can plan one round of testing for both.
Do importers have to comply with RoHS?
Yes. The E-Waste Rules treat an importer of electrical and electronic equipment as a producer, so Rule 16 applies to imported goods just as it does to goods made in India. In practice, you ask your overseas supplier for test reports and technical documents, check them against India’s limits and sign the declaration in your own name. We review the supplier’s papers before your first shipment.
Which products are covered?
The equipment listed in Schedule I of the E-Waste (Management) Rules, 2022, which covers 106 items across IT and telecom equipment, consumer electronics, large and small appliances, and more. The limits also apply to their components, consumables, parts and spares. Batteries are handled under separate rules. We match your product code against Schedule I at the start, so you know whether RoHS applies.
Are any products exempt?
Yes, some. Schedule II of the Rules lists exempted applications. The Second Amendment Rules of 24 July 2023 exempted Schedule II C equipment until 1 April 2025 and its parts and spares until 1 April 2028, where compliant alternatives are not available. Components for Schedule II B equipment placed on the market before 1 May 2014 are also exempt on the same condition. We check whether an exemption fits before you test.
Does Taxhint test the products?
No. Testing is done by accredited laboratories, and we never claim in-house testing. We handle the regulatory side: checking coverage, building the bill of materials, collecting supplier declarations, coordinating lab samples, preparing the technical file and self-declaration, and filing on the CPCB portal. The lab owns the analysis; we own the paperwork.
What is the penalty for non-compliance?
CPCB can levy environmental compensation under Rule 22 of the E-Waste Rules, and Section 15 of the Environment (Protection) Act, 1986 provides a penalty of ₹10,000 up to ₹15 lakh, with up to ₹10,000 a day if the failure continues. A false declaration can also affect your producer registration. A tested, documented product keeps you clear of it.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
The RoHS self-declaration is filed as part of producer registration on the CPCB portal, where the fee depends on your EPR target slab, from ₹2,500 to ₹15,00,000. Lab charges depend on the number of parts tested and are billed by the lab.
Ready to begin?
Send us the product list and your target markets, and we will map the RoHS testing and paperwork for India and the EU.