PDU REACH RoHS compliance comes down to three documents: a Declaration of Conformity, an SVHC disclosure against the candidate list, and a test report for the ten restricted substances. Here is what each one certifies and what to ask a PDU supplier for.
Direct answer
- PDU REACH RoHS compliance needs three documents, not one. A Declaration of Conformity, an SVHC disclosure against the candidate list, and a RoHS test report for the ten restricted substances.
- REACH and RoHS answer different questions. REACH covers the chemical safety of the article and its materials. RoHS restricts ten specific substances in electrical and electronic equipment, and a PDU is electrical equipment.
- The SVHC candidate list is the moving part. It grows twice a year, and a declaration that was valid at the last update may be out of date at the next.
- The supplier holds the documents. The importer places the PDU on the EU market and carries the legal exposure, so the documents have to be requested at the ordering stage, not discovered at customs.
- Newsunn holds the test reports and declarations for its PDU range. The compliance documents page lists the ISO 9000, CE, UL, EESS and GS certificates plus the REACH test report to the 2021 SVHC list.
The specification this article works from is published on our compliant PDU products page, our data center rack PDU exporter product and our compliance documents page. The question importers ask is which certificates they actually need, and the honest answer starts with which regulation answers which question.
Most requests our engineering team answers come from data center and IT infrastructure buyers sourcing PDUs for the EU market. Across more than a decade of PDU design and manufacturing, the compliance failures we see almost always trace to a single missing document, not to a substance failure. The substance was compliant; the paper was not.
The confusion is understandable, because the two regulations appear in the same supplier questionnaire and the same procurement conversation. REACH and RoHS both restrict hazardous substances, both apply to the EU market, and both generate a certificate with a reference number. But they answer different questions, and a compliance file that treats them as one regulation is a compliance file with a hole in it.
REACH and RoHS Answer Different Questions
REACH and RoHS are two separate EU regulations, and a PDU importer needs both. REACH, Regulation EC 1907/2006, is the framework for registering, evaluating, authorising and restricting chemical substances in the EU. It covers the chemical safety of the article and the materials it is made from. RoHS, Directive 2011/65/EU, restricts the use of ten specific hazardous substances in electrical and electronic equipment. A rack PDU is electrical equipment, so it falls inside the RoHS scope.
The two overlap but do not substitute. REACH asks whether the PDU contains any substance on the SVHC candidate list above 0.1 percent by weight in any component. RoHS asks whether the PDU contains any of the ten restricted substances above the threshold in the homogeneous material. Because the two regulations ask different questions, so a PDU can pass REACH and fail RoHS, or the reverse, and an importer who holds only one certificate is exposed on the other.
The scope difference matters in practice. REACH applies to every article placed on the EU market, whether it is electrical or not. RoHS applies specifically to electrical and electronic equipment. A rack PDU is unambiguously inside the RoHS scope, so a PDU importer cannot argue that RoHS does not apply. The European Commission REACH overview sets out the registration, evaluation, authorisation and restriction process that REACH operates.
| Regulation | Scope | What it asks | Document |
|---|---|---|---|
| REACH EC 1907/2006 | All chemical substances in articles | Any SVHC above 0.1% by weight | SVHC disclosure, Declaration of Conformity |
| RoHS 2011/65/EU | Electrical and electronic equipment | Any of ten restricted substances above threshold | RoHS test report |
The Three Documents
PDU REACH RoHS compliance is a paperwork exercise before it is a chemistry exercise, and the paperwork has three parts.
Declaration of Conformity
The Declaration of Conformity is the supplier’s signed statement that the PDU meets the applicable EU legislation. It names the directives, the standards applied, and the manufacturer or importer who takes responsibility. For a PDU going into the EU, the Declaration covers the Low Voltage Directive and the EMC Directive alongside REACH and RoHS. It is the document a market surveillance authority asks for first.
SVHC disclosure
The SVHC disclosure states whether the PDU contains any substance on the ECHA candidate list above 0.1 percent by weight in any component. The candidate list grows twice a year, and a disclosure that was valid at the last update may be out of date at the next. The European Commission REACH overview sets out the registration and evaluation process and the authorisation track for SVHCs. For an importer, the SVHC disclosure is the document that has to be refreshed at each candidate list update, not once per programme.
RoHS test report
The RoHS test report is the laboratory result for the ten restricted substances. The RoHS Directive restricts lead, cadmium, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP. The test report confirms the PDU is below the threshold in each homogeneous material. For a rack PDU, the test covers the housing, the PCB, the wiring, the outlets and the plug. The RoHS Directive entered into force on 21 July 2011 and has been amended by delegated directives since.
The test report is the document that ages slowest. The ten restricted substances have been stable since the 2015 delegated directive added the four phthalates, and the thresholds have not moved. A RoHS test report from a competent laboratory stays valid for the life of the product, which is why it is the document a supplier can produce most readily.
What to Ask a PDU Supplier
The importer carries the legal exposure, so the documents have to be requested at the ordering stage, not discovered at customs. The EU market surveillance regime places the obligation on the economic operator who places the product on the market, and for a PDU imported from China, that is the importer, not the factory.
Ask the supplier for the Declaration of Conformity naming the LVD, EMC, REACH and RoHS directives, the SVHC disclosure against the current candidate list version, and the RoHS test report from an accredited laboratory. Newsunn publishes its compliance documents on the certificate page, including the ISO 9000 system certification, the CE declaration for the European market, the UL certificate for the US market, the EESS certificate for the Australian market, the GS 4061 M2 certificate and the REACH test report to the 2021 SVHC list of 209 substances.
The request should go in at the ordering stage, not at the shipping stage. A supplier who has the documents can produce them in days. A supplier who does not have them needs weeks to commission the test and draft the declaration, and those weeks land in the delivery window if the request arrives late. Because the compliance file has to be complete before the first container leaves the factory, so the request belongs at the ordering stage, not the shipping stage.
Because the importer is the economic operator named at the border, so the importer carries the exposure, and the three documents are the only defence.
Verifying the Documents Before the Order
A buyer who wants to verify the compliance file before placing the order has three checks to run. The first is to confirm the Declaration of Conformity names the correct directives and is signed by the manufacturer, not by the trading company. The second is to confirm the SVHC disclosure references the current candidate list version, not an outdated one. The third is to confirm the RoHS test report comes from an accredited laboratory and covers the full product, not just a component.
The verification step costs the buyer nothing and closes the gap between the promised compliance and the delivered compliance. A supplier who can produce the three documents on request has the compliance file in place. A supplier who cannot is describing a file they intend to assemble. For a data center programme that runs over several years, the verification step at the first order is the cheapest insurance in the procurement process, and the three-document check is the single most reliable quality assurance step available to a PDU importer before a bulk order is placed.
Frequently Asked Questions
What is the difference between REACH and RoHS for a PDU?
REACH covers the chemical safety of the article and its materials, asking whether any SVHC on the candidate list is present above 0.1 percent by weight. RoHS restricts ten specific substances in electrical and electronic equipment above the threshold in each homogeneous material. A PDU is electrical equipment and falls inside the RoHS scope. An importer needs both.
What documents does a PDU importer need for EU compliance?
Three documents. A Declaration of Conformity naming the applicable directives. An SVHC disclosure against the current candidate list version. A RoHS test report for the ten restricted substances. Each document answers a different question, and an importer who holds only one or two is exposed on the rest.
How often does the SVHC candidate list change?
The ECHA candidate list is updated twice a year, typically in January and July. A disclosure that was valid at the last update may be out of date at the next. The SVHC disclosure is the document that has to be refreshed at each candidate list update, not once per programme.
Does a PDU need both REACH and RoHS certification?
Yes. REACH and RoHS answer different questions and a PDU importer needs both. REACH covers chemical safety across all substances. RoHS restricts ten specific substances in electrical equipment. A PDU can pass one and fail the other.
What certifications does Newsunn hold for its PDU range?
Newsunn publishes ISO 9000 system certification, the CE declaration for the European market, the UL certificate for the US market, the EESS certificate for the Australian market, the GS 4061 M2 certificate and the REACH test report to the 2021 SVHC list of 209 substances. The documents are listed on the Newsunn certificate page.
Who carries the legal exposure for a non-compliant PDU?
The economic operator who places the product on the EU market, which for an imported PDU is the importer, not the factory. The importer carries the exposure and the three compliance documents are the only defence.
With over a decade of hands-on experience in PDU design and manufacturing, Newsunn’s technical team provides in-depth insights into power distribution solutions for data centers, server rooms, and mission-critical facilities. Backed by 8 R&D engineers and a 30,000 m² production base, we help global clients source the right PDU products, from standard rack units to fully customized intelligent power distribution systems.
Last verified: 2026-11-06. Certification scope, product specifications and company details are as published on the Newsunn product, certificate and about pages on 6 November 2026. REACH and RoHS regulation scope is as published on the European Commission environment pages. Regulation versions and candidate list updates change; confirm the current compliance status directly with the issuing body before relying on any certificate.
Post time: Nov-06-2026