RoHS REACH Compliance for Power Equipment

XIAOPAI - Wenzhou Xiaopai Electric Power Technology Co., Ltd. - manufactures the power transmission equipment line in Wenzhou, Zhejiang: transformers, vacuum circuit breakers and switchgear. When an EU buyer opens a compliance file, the conversation usually starts and ends with the CE mark. It should not. Behind the CE file sits a second layer - material compliance - with its own directives, its own documents and its own failure points on power equipment.

1. WHY THE CE MARK IS NOT THE WHOLE FILE

CE covers the safety and electromagnetic side of electrical equipment - the Low Voltage Directive (2014/35/EU) and the EMC Directive (2014/30/EU) - backed by a Declaration of Conformity and technical documentation. RoHS is both part of that family and something else: it is a CE directive, so a RoHS statement belongs inside the same declaration, but it says nothing about how the equipment performs. It says what the equipment is made of. REACH sits outside the CE system entirely, with its own duties. The distinction matters for the transformers and switchgear XIAOPAI manufactures because the restricted substances cluster in the same places on every build: solders, coatings, cable jacketing, insulation and plastics.

2. WHAT ROHS ACTUALLY RESTRICTS

Directive 2011/65/EU, as amended by (EU) 2015/863, restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates - DEHP, BBP, DBP and DIBP - which became applicable on 22 July 2019. The limits bite at homogeneous material level: 0.01% (100 ppm) for cadmium, 0.1% (1,000 ppm) for the other nine. On power equipment, four locations carry most of the risk. Solder joints carry lead unless the process is lead-free. Metal parts can carry hexavalent chromium in anti-corrosion passivation. Cable jacketing carries the phthalate plasticizers that make PVC flexible - the material trade-offs are set out in this piece on PVC as jacketing material. And insulation systems carry flame retardants and, in some chemistries, further restricted substances - a subject covered in insulating materials in electrical equipment.

3. THE SCOPE QUESTION: LSFI AND LSIT

RoHS 2 has an open scope, with two exclusions that come up in this industry: large-scale fixed installations (LSFI) and large-scale stationary industrial tools (LSIT). Suppliers sometimes cite them broadly. The EU guidance is narrower and case-by-case: the assessment turns on the item as placed on the market - a product offered as a single functional unit is assessed as that unit, whatever its size, and being part of a larger installation does not exempt the components inside it. That is the line to watch on substation and grid hardware. The question for a buyer is not "are you RoHS compliant" but "how was the scope decision made for this product, and where is it written down".

4. REACH: THE 0.1% LINE AND THE SCIP DATABASE

REACH (EC) 1907/2006 works differently from RoHS. It does not set substance bans for equipment; it attaches duties to articles that contain a substance of very high concern (SVHC). The candidate list now holds 253 entries, after the 4 February 2026 update added n-hexane and bisphenol AF with its salts - substances whose uses include polymer processing, coatings and cross-linking. The trigger line is 0.1% by weight. Above it, the supplier must pass safe-use information down the chain and answer consumer requests within 45 days (Article 33); importers placing more than one tonne per year of the article must notify ECHA; and the article must be registered in the SCIP database, live since 5 January 2021. For a transformer, that means the material data has to come up from insulation, compound and cable suppliers - a data path, not a one-page letter.

5. WEEE AND THE END-OF-LIFE SIDE

WEEE (2012/19/EU) places duties on whoever puts the equipment on the EU market: producer registration in the member state and end-of-life take-back or recycling arrangements. For a non-EU manufacturer such as XIAOPAI, the practical route runs through an EU importer or authorised representative. The question worth asking in the tender is which entity carries that registration, and in which member states the equipment will be placed.

6. THE FILES TO ASK FOR

RoHS: a Declaration of Conformity that names RoHS alongside LVD and EMC; technical documentation built to EN IEC 63000:2018; material declarations from sub-suppliers; and test reports for high-risk materials. REACH: an SVHC declaration that states the candidate list version it was checked against - a statement dated before the latest update has not seen the newest entries - plus SCIP registration numbers where the threshold is exceeded. WEEE: the registration route, named in the contract. One habit ties the three together: check the date and the version of every document, not just its existence. Material compliance is a chain of dated statements, and an undated one proves nothing.

7. THE SUPPLY ROLE

XIAOPAI manufactures the power transmission equipment line - the S9-S22 sealed oil-immersed transformer range and the SCB epoxy-cast dry-type range, both rated up to 35 kV, among it - and handles equipment integration and export documentation for each order. The material file is a document set, not a sticker; it is assembled per project and per destination market, which is why the checks above are worth writing into the tender instead of assuming at the end. The two transformer ranges are on the oil-immersed transformer and dry-type transformer pages.

RoHS and REACH Compliance: What EU Buyers of Power Equipment Should Check