Factories targeting the UK market, take note: CE RoHS is not the same piece of paper as EU CE. After Brexit, the UK introduced UKCA, but for RoHS they retained a separate regulation — UK RoHS. Simply put, it controls six hazardous substances in your products — lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ethers — which must not exceed limits, and later four phthalates were added. Regardless of whether your customer asks you for CE RoHS or UK RoHS, the essence is restricting these substances, but the legal basis and enforcement body are different. If you use an EU CE RoHS report to satisfy a UK customer, and you run into strict customs clearance or market surveillance, they really can block you.
Which products need it? Electrical and electronic equipment basically can't escape. Consumer small appliances, IT equipment, lighting fixtures, power tools, toys with batteries, medical devices (some exempt), surveillance equipment — all are in scope. Don't think only finished products are covered; your wiring, plastic parts, PCB boards, solder, and inks used in packaging — every link in the supply chain must have a substance declaration. I've seen too many factories whose complete-unit test passed, but because a power cord supplier changed material and cadmium exceeded limits, the entire batch was detained at the port during sampling inspection. So you must sort out the BOM clearly and ask every supplier for a RoHS report or declaration for each component — don't find it troublesome.
There are three most common pitfalls. First, passing off an EU report as a UK report. Although test methods are similar, the regulation numbers and limit versions cited in the report must match current UK requirements; if the customer or customs sees the regulation number is wrong, it's rejected outright. Second, testing only the complete unit and not homogeneous materials. RoHS is judged by homogeneous material, not by grinding up the whole unit and testing it — one screw's coating exceeding limits makes the whole unit non-compliant. Third, ignoring the validity period of exemption clauses. For example, lead in certain high-temperature solders is exempt, but you must watch the exemption expiry date; if no alternative is found before expiry, the report becomes invalid. Also, don't trust those "certificate in three days" outfits — properly doing homogeneous material disassembly testing takes several days just for disassembly and queuing.
On turnaround time, for conventional products, from sample submission to report issuance, if smooth, five to seven working days; for complex products such as multi-material and multi-color ones, with more disassembly and test items, two weeks is normal. If testing fails, you have to change materials, switch suppliers, and resubmit samples — one round trip costs a month. So before quoting a UK customer, first confirm the validity and coverage of the RoHS report; don't wait until the shipping schedule is set to supplement it — at that point the expedite fee costs more than the test fee. Remember, the report is for customers and regulators to see, not for yourself — regulation version, homogeneous material list, exemption citations — none can be missing.