SWTC SWC · Kenya

RoHS Report Ruled Invalid: Whole Product Tested, Homogeneous Materials Not Tested

Published in English.

The customer, to save costs, asked the laboratory to "just test the whole unit once."

Whole-unit mixed digestion diluted the excessive cadmium below the limit, and the report showed compliance; during the customer's factory audit, they requested homogeneous material disassembly data, which could not be provided.

Re-disassembly by homogeneous material: PVC sheath, copper conductor, solder joints, and terminal plating were sampled separately. Priority testing was conducted on high-risk materials, and the source of exceedance was identified as cadmium in recycled PVC. The supplier was replaced and required to provide a material declaration and batch test reports. The BOM and homogeneous material correspondence table were rebuilt to form traceable technical documentation.

After locating and replacing the material, retesting passed, and the customer's factory audit was closed out. The cost of rework and retesting was approximately 2.6 times the original quotation.

RoHS is judged by homogeneous material; whole-unit mixed testing does not hold up in audits. Recycled materials are a high-incidence source of cadmium and lead exceedances and need to be controlled at the supplier admission stage. The value of technical documentation lies in traceability, not in a single report.

Reversing that order usually costs an extra round of sample and an extra round of testing.

Prepared by the Shuwang certification engineering team from live project records.

Service boundary: Shuwang Certification Platform is an export certification solution provider. It does not perform testing and is not a certification body. Testing described on this page is carried out by partner laboratories accredited to CNAS/CMA or ISO/IEC 17025; certificates are issued by EU Notified Bodies or by the authorised bodies of the destination country. Lead times and cost ranges are public industry references and depend on engineer assessment and body scheduling.

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