Risk & Traceability

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Last updated: October 2026



Compliance Risk and Supply Chain Traceability

RoHS, REACH and conflict minerals rules put the burden of proof on the company that places a product on the market. That company rarely makes every part itself, so the evidence of compliance has to come from suppliers - often several tiers deep. Traceability is the paperwork chain that carries that evidence from raw material to finished product, and compliance risk is what happens when a link in that chain is missing or wrong.

The traceability chain

  1. Supplier declarations - what substances are in each part, from yes/no RoHS statements to full material declarations. See Supplier Material Declarations.
  2. Compliance assessment - the manufacturer's technical documentation under EN IEC 63000 and the RoHS Declaration of Conformity that supports CE marking.
  3. Notifications and disclosure - REACH Article 33 communication of SVHCs to customers, SCIP database notifications in the EU, and SEC Form SD filings in the US.
  4. Sourcing due diligence - smelter and refiner identification for tin, tantalum, tungsten, gold, cobalt and battery minerals. See Conflict Minerals Reporting.

Where compliance risk comes from

  • Stale data - the REACH SVHC Candidate List grows roughly twice a year, and RoHS exemptions expire, so declarations collected once go out of date.
  • Supplier changes - an alternate source or a process change at a sub-tier supplier can introduce a restricted substance without a part number change.
  • Certificates without data - a signed certificate of compliance gives no substance data to re-check when the rules change.
  • New substance classes - PFAS restrictions reach materials, such as fluoropolymers, that earlier RoHS-only programs never tracked.

Compliance software

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