RoHS compliance series. This article is how to verify a RoHS report and spot fakes. Start at the hub: What RoHS Actually Is: Directive 2011/65/EU Explained.
Ten minutes. That's all it takes to kill most borrowed or mismatched RoHS documents — because the reports that fool people aren't clever. They're just never read.
I've sat across from buyers holding a certificate that didn't match the report number, for a model they didn't ship, with six substances on a page that should have had ten. Nobody checked. Nobody had time. The scam doesn't need to be good; it just needs you to skip the check.
So here's the six-step verification, the same one our own RoHS documents have to survive:
The Six-Point Checklist
| Check | What to verify | Where |
| 1. Certificate matches report | The certificate cites a report number; the report exists with that number | Both documents |
| 2. Model matches | Product name and model match your SKU | Cover page and certificate |
| 3. Scope covers your materials | The tested materials match your product's components | Sample description |
| 4. Standard versions are current | 2011/65/EU + (EU) 2015/863, EN 62321 series with amendment years | Standards and methods lines |
| 5. All ten substances are covered | Metals, PBB/PBDE and the four phthalates all present | Result summary |
| 6. Methods and MDLs are stated | Instruments listed, detection limits visible | Result pages |
Check 3 in Detail: The Material Scope
The sample description is where most verification fails. Our report names the tested material — grey fabric, non-metal, one sample — which tells the reader exactly what was measured. A report that says "the product passed" without naming materials cannot be matched to your bill of materials. Ask which homogeneous materials were tested and compare the list with your product.
Check 4 in Detail: The Standards
Two lines matter:
- The directive scope — 2011/65/EU with the (EU) 2015/863 amendment. A report citing only the original directive predates the phthalate requirement.
- The methods — the EN 62321 series with amendment years (ours cites -4:2014+A1:2017, -5:2014, -6:2015, -7-2:2017, -8:2017). Dated standards are part of the evidence.
Check 5 in Detail: The Ten Substances
The result summary should show three groups: the four metals, the PBB/PBDE families, and the four phthalates. A summary missing the phthalate line is a six-substance report, not a ten-substance one — and it is not the current scope.
Check 6 in Detail: Methods and Detection Limits
Two details separate a real report from a summary:
- The instruments — ICP-OES and UV-Vis for the metals, GC-MS for PBB/PBDE and phthalates. No method list, no verifiable scope.
- The detection limits — N.D. only means something with the MDL attached (ours: 2 mg/kg metals, 5 mg/kg congeners, 50 mg/kg phthalates). No MDL, no meaning.
The Red Flags
- A certificate with no report number. The certificate should cite its report.
- No material scope. A RoHS report that does not name what was tested covers nothing you can verify.
- Only six substances. A pre-2019 scope missing the phthalates is not the current standard.
- No methods or MDLs. A report that hides how it measured is hiding its standards.
- Model mismatch. A report for another model covers nothing.
- A "CE certificate" sold as a shortcut. RoHS evidence is part of the CE folder, not a replacement for the importer's declaration.
- Claims beyond the document. The certificate covers one sample, not the whole production — anyone claiming "whole production certified" is overstating.
We publish this checklist because our own RoHS documents have to survive it. Every request for our RoHS evidence gets the same response: the report with the scope and methods, the certificate with the report number, and a straight answer about which materials are covered. A buyer who cannot verify a document should not trust it — and we would rather lose the sale than the trust.
What a Complete Set Looks Like
Using our Model 1338 as the example:
| Element | What it shows |
| Report No. S250827030001-1 | Scope (grey fabric), standards, methods, limits, results |
| Certificate No. S250827030001-2 | Cites the report, names the product, states the conclusion |
| Sample description | One non-metal sample — scope visible and matchable |
| Result pages | Ten substances, MDLs, flow charts for each method |
Every element cross-references another. That's what a genuine document chain looks like — and it's exactly what borrowed or fabricated documents cannot produce.
Frequently Asked Questions
How do I know a RoHS report is current?
Check the directive scope (2011/65/EU + (EU) 2015/863), the standard versions with amendment years, and the report date. The ten-substance scope is the current baseline.
Is a certificate enough for RoHS verification?
No — the certificate is a summary. The report holds the scope, methods, limits and results, and the two must be read together.
What does a missing detection limit mean?
It means the N.D. results cannot be interpreted. N.D. only means "below the MDL" — without it, the report is hiding its own standards.
Which substances must a complete RoHS report cover?
All ten: lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and DEHP, BBP, DBP, DIBP. A six-substance scope predates the phthalate amendment.
Do I need to verify the lab?
Yes — confirm the lab's identity, the report number and the certificate's consistency. The report's internal cross-references are the evidence.
How quickly can CLK provide its RoHS documents?
Same day on request — the report, the certificate, the scope and the methods, with a plain explanation of what is covered. Contact clkbusiness@clkluggage.com or WhatsApp +86-18879628221.
About the Author
Written by the CLK Manufacturing Team — 16+ years of custom luggage OEM/ODM experience from our factory in Ji'an, Jiangxi, China. Updated: 2026-08-15.
Related Products & Sourcing
CLK Luggage (Jiangxi Chengleke Leather Co., Ltd.) manufactures custom hard-shell luggage, aluminum-magnesium cases and luggage sets for brands, retailers and corporate clients. Relevant resources:
- Browse our luggage sets and custom OEM/ODM luggage manufacturing
- Why choose CLK — factory profile, quality control and certifications
- Get a quote: contact our team or email clkbusiness@clkluggage.com