Two different instruments
RoHS and REACH are often mentioned together, but they work differently.
- RoHS (Directive 2011/65/EU, known as RoHS 2) restricts certain hazardous substances in electrical and electronic equipment. It is a product rule with a defined list of restricted substances and concentration limits, and it uses a declaration of conformity and, where applicable, CE marking.
- REACH is the EU's broader chemicals regulation. For buyers of finished articles such as cable, the question usually raised is whether the article contains substances of very high concern (SVHC) from the candidate list, and what information has to be passed down the supply chain.
The desk has verified the RoHS position for cable from European Commission guidance. REACH was outside the scope of our standards research, so this article does not state what REACH requires for a particular cable; it explains how to ask the plant for the declaration your customer requires, and leaves the legal assessment to your importer of record or compliance adviser.
RoHS 2 and cables
The first RoHS directive did not clearly cover cable sold on its own. RoHS 2 changed that. According to the European Commission's RoHS FAQ guidance, RoHS 2 extended the scope to all electrical and electronic equipment, including cables. Cables that had not been in the scope of the first directive could be treated under the open-scope category 11, with a transition period that ended on 22 July 2019. Since then, cable sold in the EU has been expected to meet the substance restrictions.
A separate question is whether a cable sold on its own needs its own EU declaration of conformity and CE marking under RoHS. Europacable, the European cable industry association, published an interpretation in 2019: cables sold separately with a rated voltage below 250 V need an EU declaration of conformity and CE marking, while cables rated 250 V and above do not carry that obligation, though they must still meet the substance restrictions. That is an industry association reading, not a court ruling, so confirm how it applies to your product with your importer of record.
| Cable example | Rated voltage | Substance restrictions | RoHS declaration and CE marking |
|---|---|---|---|
| Cat6 U/UTP data cable | Below 250 V | Apply | Needed when sold separately |
| Coaxial cable such as RG6 | Below 250 V | Apply | Needed when sold separately |
| 300/500 V flexible cord | 250 V and above | Apply | Not required by RoHS itself |
| 450/750 V building wire | 250 V and above | Apply | Not required by RoHS itself |
| 0.6/1 kV power cable | 250 V and above | Apply | Not required by RoHS itself |
Two points keep this from being misread. First, the cable may still need CE marking for another reason: building cable under the Construction Products Regulation carries a DoP and CE marking for its reaction-to-fire class, as explained in EU CPR for cables. Second, optical fibre cable without metallic conductors raises its own scope question; ask your adviser rather than assuming.
What a useful RoHS file looks like
A single RoHS test report from a laboratory, with no link to a construction, tells you little. Cable is made from several compounds: insulation, sheath, fillers, tapes and sometimes colour masterbatch. Any of them can change between batches or suppliers. A useful file connects the report to what you are buying:
- Construction reference: the report or declaration names the cable type, the compounds tested and, ideally, the compound supplier and grade.
- Directive version: the report is against RoHS 2 and its current list of restricted substances, not an outdated list.
- Date and validity: a recent report, with the plant's statement that the compound formulation has not changed since.
- Declaration: for cables below 250 V sold separately, the EU declaration of conformity issued by the responsible party.
- Change control: a commitment to notify you before changing a compound supplier, recorded in the order terms.
LSZH compounds are sometimes assumed to settle the question automatically. They do not. LSZH describes fire behaviour, tested to IEC 61034 and IEC 60754-1/-2; substance compliance is a separate test and a separate declaration. The insulation and sheaths page explains the compound families.
REACH: ask for the declaration your customer needs
Because the desk has not verified the REACH obligations for cable, the practical approach is to work backwards from your customer. Large retailers, distributors and project owners often have a standard supplier declaration with their own wording, and some ask for a statement about SVHC from the current candidate list. The steps are simple:
- Get your customer's required wording or template before production, not after shipment.
- Ask the partner plant for the SVHC declaration your customer requires, naming the candidate list version and the cable construction it covers.
- Where the plant relies on its compound suppliers' declarations, ask for those too, so the chain is visible.
- Have your importer of record or compliance adviser review the wording before it goes to your customer.
The desk collects and checks these documents for completeness and consistency with the construction, but does not issue legal opinions on REACH compliance and does not state that a cable is REACH compliant on the plant's behalf.
Building substance documents into the order
Substance documents are cheap to arrange at the start and expensive to chase after the goods have shipped. Name them in the RFQ alongside the construction and fire documents, and they become part of the plant's quotation and lead time. The desk files them with the routine test records and the quality control checks for each order, so one shipment file holds the DoP, the RoHS report and declaration, the SVHC declaration and the conductor resistance records.
For private label buyers this matters more, because the brand on the box is the one your customer contacts. Agree with your importer who issues each declaration and in whose name; the OEM and private label page explains how the desk coordinates documents for branded orders. When you are ready, list the documents you need in the quote request, together with the destination and the end customer's requirements.