CE, RoHS, REACH Compliance Guide for Electrical Enclosures: EU Market Access

This article covers the following content

If you are an electrical wholesaler or EPC procurement professional working on EU projects or preparing to export to the EU, this article will help you understand:

1. What exactly does the CE marking cover? Do electrical enclosures require CE marking?

2. What hazardous substances are restricted by RoHS? What documents should be reviewed during procurement?

3. What are the differences between REACH and RoHS? Why are EU customers starting to require a REACH declaration?

4. Four most common questions about EU compliance in procurement

This article is byBSUMWELLWritten by our technical team, we are a manufacturer specializing in waterproof electrical enclosures. Our products cover three major material series: PC/ABS plastic, stainless steel, and aluminum enclosures, with protection levels ranging from IP55 to IP68. We support OEM/ODM customization.

Why must we pay attention to CE, RoHS, and REACH when exporting to the EU?

The CE mark – a "passport" to the EU market.

The CE marking is a mandatory compliance mark for products entering the EU market. Without the CE marking, a product cannot be sold within the EU.

The CE mark is not a "certification", but a "declaration".

The logic is that manufacturers declare their products comply with relevant EU directives and affix the CE mark. However, "self-declaration" does not mean that products can be affixed arbitrarily — if non-compliance is discovered during a market inspection by regulatory agencies, the consequences are severe: product removal from shelves, fines, and even criminal prosecution.

The CE marking covers multiple directives.Related to electrical enclosures include:

• LVD (Low Voltage Directive): Involving electrical safety

• EMC (Electromagnetic Compatibility Directive): Electromagnetic interference is involved.

• RoHS (Restriction of Hazardous Substances Directive): Environmental protection requirements are involved.

For casing products, the most crucial factor is RoHS compliance. — Because the casing is a component of electronic and electrical equipment, it must comply with RoHS requirements for hazardous substances.

RoHS and REACH—Two Easily Confused Environmental Directives

RoHS and REACH are both EU environmental regulations, but their scope of application is completely different.

• RoHS: against Electronic and electrical equipment, limit 10 specific hazardous substances The concentration.

• REACH: against All chemicals Regulation Tens of thousands of chemical substances It requires companies to register, be evaluated, authorized, and subject to restrictions.

Simply put: RoHS regulates "what cannot be in a product", while REACH regulates "how chemicals are used safely".

For electrical enclosures:

• RoHS: As an accessory for electronic and electrical equipment, the casing must comply with RoHS.

• REACH: If the casing contains more than 0.1% SVHCs (substances of very high concern), the customer must be informed.

More and more EU customers are requiring a REACH SVHC compliance declaration in addition to a RoHS declaration when making purchases.

CE Mark Explained – Which Directives Must Electrical Enclosures Comply With?

The directive framework for the CE marking (LVD, EMC, RoHS)

The CE marking is not a single certification, but rather a collective term for a product's compliance with a series of EU directives. The directives related to electrical enclosures mainly include:

Key conclusion: Empty casings typically do not require separate CE certification (because they are not electrically charged and do not generate electromagnetic interference), but must comply with RoHS. If the enclosure integrates electrical components (such as fans, heaters, and thermostats), then the applicability of LVD/EMC needs to be assessed based on the specific components.

Do empty shells require CE marking? — It depends on the situation.

Many buyers ask, "Do your enclosures have CE certification?"

This question needs to be answered depending on the situation:

Scenario 1: Empty casing (without any electrical components)

• CE marking is usually not required.

• However, it must comply with RoHS (as accessories for electrical and electronic equipment).

• After the customer assembles the complete equipment, the OEM is responsible for CE compliance.

Scenario 2: The casing contains electrical components (such as fans, heaters, and lighting).

• It is necessary to assess whether these components fall within the scope of LVD/EMC.

• If so, the entire machine requires CE certification.

• As part of the overall device, the casing needs to comply with regulations in cooperation with the device manufacturer.

Scenario 3: The casing is sold to the end user as a separate product.

• If the enclosure itself does not constitute an "electrical device", CE certification is usually not required.

• However, RoHS compliance is required.

Our products are mainly empty shells and do not usually require CE marking, but we ensure that our products comply with RoHS standards. If customers require the integration of electrical components, we can provide relevant materials and testing support. Learn about our RoHS compliance statement

RoHS Directive – Which hazardous substances are restricted?

RoHS List of 10 Restricted Substances

The RoHS Directive (EU 2011/65/EU) currently restricts the following 10 hazardous substances:

These substances are mainly found in:

• Flame retardants and plasticizers in plastics

• Alloy composition and coating in metals

• Solder in electronic components, batteries

For electrical enclosures RoHS compliance mainly focuses on:

• Flame retardants and plasticizers in plastic casings

• Alloy composition and surface treatment in metal casing

• Plasticizers in sealing strips

RoHS Compliance Declaration and Test Report – What Do Purchasers Need to See?

When purchasing parties request RoHS compliance documents from suppliers, they typically encounter two forms:

What should the purchasing party look for?

• For standard products: a RoHS compliance declaration is usually sufficient.

• For high-risk products or large orders: it is recommended to request a third-party test report.

• Note the report's validity period and the models it covers — one report corresponds to only one model or batch.

Our products comply with RoHS standards, and a compliance declaration can be provided upon request. If a third-party test report is required, we can assist the client in arranging the test.

REACH Regulation – A broader regulation of chemicals than RoHS

REACH SVHC List – What are Substances of Very High Concern?

REACH (EC 1907/2006) is the EU's comprehensive regulatory framework for chemicals. Among its provisions, the one most relevant to product procurement is ... SVHC (Substances of Very High Concern) List.

Characteristics of SVHC lists:

• Released by the European Chemicals Agency (ECHA)

• It currently contains more than 200 substances (Data source: ECHA official website, continuously updated).

• The list is updated regularly (with new additions each year).

• If the SVHC content in the product exceeds 0.1% (by weight), this information needs to be communicated to the customer.

For electrical enclosures, the following should be considered:

• Plasticizers and flame retardants in plastics

• Chemicals in metal surface treatment

• Additives in sealing strips

The core of REACH compliance is "information transmission": If a product contains more than 0.1% SVHCs, the supplier needs to inform the customer so that the customer can fulfill their compliance obligations.

RoHS vs REACH - A table to understand the differences

How do I use this table?

1. Confirm whether you need to focus on "restricted substances" or "chemical regulations".

2. Find the corresponding compliance requirements in the table.

3. Note that the two have completely different regulatory scopes and compliance methods.

Simply put: RoHS governs "10 substances that must not exceed the limit", while REACH governs "all chemicals must be safe".

Frequently Asked Questions (FAQ) about Procurement

Q: Does an empty shell need a CE mark?

A: A bare enclosure typically does not require CE marking because it does not constitute an electrical device. However, if the empty enclosure is used as an accessory to an electronic or electrical device, it must comply with RoHS. If the enclosure integrates electrical components (such as fans or heaters), it is necessary to assess the applicability of LVD/EMC based on the specific components, and the entire unit may require CE marking.

Q: What is the difference between a RoHS compliance declaration and a test report?

A: A compliance statement is issued by the supplier themselves; it's low-cost but lacks third-party verification. A test report is a testing report issued by a third-party laboratory; it's highly credible but expensive and time-consuming. For routine products, a compliance statement is usually sufficient; for high-risk products or large orders, it's recommended to request a test report.

Q: What is the difference between REACH and RoHS?

A: RoHS restricts 10 specific hazardous substances and applies to electrical and electronic equipment. REACH regulates all chemicals and currently includes over 200 SVHCs, requiring that customers be informed if the SVHC content exceeds 0.1%. The two are complementary, not substitutable.

Q: What compliance documents can you provide?

A: We can provide:

• RoHS compliance declaration (available upon request)

• REACH SVHC Compliance Declaration (available upon request)

• Material certification (MTC, for stainless steel/aluminum casings)

• If needed, we can assist clients in arranging third-party testing.

Our products cover IP55 to IP68 protection ratings, and are made of materials including PC/ABS plastic, stainless steel, and aluminum housings. Contact us to obtain compliance documents

Summary of the key points of this article

1. The CE mark is not a single certification. — It is a collective term for products that comply with a series of EU directives.

2. Empty casings typically do not require CE marking. — But it must comply with RoHS.

3. RoHS restricts 10 hazardous substances — Review compliance statements or test reports when making purchases.

4. REACH has a broader scope than RoHS. — Regulate all chemicals; information must be communicated for SVHC > 0.1%.

5. We can provide a RoHS/REACH compliance declaration.—Available upon request to assist clients in achieving compliance.

(Previous article: Understanding UL Certification in the North American Market? Please read the second article in this series, "...")UL Certification Explained: UL 50E vs UL 508A – Certifications You Must Understand When Exporting to North America》)