The European Commission’s latest Joint Actions on Compliance of Products (JACOP) project offers a useful starting point for understanding why products can still fail environmental compliance checks even when manufacturers have established compliance programs.

Published in June 2026, the JACOP project brought together market-surveillance authorities from 13 European countries to assess 173 electrical and electronic products. Authorities combined laboratory testing with reviews of technical documentation, CE marking, traceability, and conformity assessment. According to the European Commission’s JACOP findings, 91 products, or 53%, were found to be noncompliant.

The 53% figure must be interpreted carefully. It doesn’t mean that 53% of the products exceeded restriction of hazardous substances (RoHS) concentration limits. The finding includes documentation deficiencies, such as missing or incorrect CE marking and traceability information, together with other regulatory shortcomings and laboratory failures. The important point is that regulators are assessing both the physical product and the systems used to demonstrate that the product complies.

That distinction matters. A product can have acceptable laboratory results but still present a compliance problem if its technical documentation, conformity records, or traceability can’t demonstrate that the evidence relates to the product actually being placed on the market. Conversely, documentation can’t compensate for a physical product that contains restricted substances above applicable limits.

A broader enforcement signal

The broader EU enforcement picture points in the same direction. The European Commission’s Safety Gate Report 2025 recorded 4,671 alerts and 5,794 follow-up actions. Chemical risks accounted for 53% of all notifications, although this figure covers all product categories monitored through Safety Gate and should not be interpreted as a failure rate for RoHS, REACH (the EU’s registration, evaluation, authorization, and restriction of chemical substances), or POPs (persistent organic pollutants).

See the European Commission Safety Gate Report 2025 for the underlying figures. The more useful lesson for manufacturers isn’t the headline number but the increasing expectation that compliance evidence accurately reflects the product, its configuration, and its supply chain.

Why compliance information falls out of date

Environmental compliance programs were often built around supply chains that changed relatively slowly. Supplier documentation was collected, technical files established and restricted-substance databases maintained. That created a solid foundation for compliance.

Now, products and supply chains can change much faster. Component shortages have accelerated the use of alternate parts. Manufacturers qualify second-source suppliers, move production between facilities, and change materials in response to cost, performance, and sustainability objectives. At the same time, regulations continue to evolve through new substance restrictions, updated guidance, and changing RoHS exemptions.

The recent revision of several RoHS lead exemptions illustrates the point: Compliance obligations can change even when a product’s design or bill of materials remains unchanged, requiring manufacturers to reassess existing compliance evidence. The European Commission’s delegated directives on RoHS lead exemptions and related amendments show how the regulatory baseline itself can move.

One misconception I encountered repeatedly during my years leading environmental compliance programs was the assumption that an engineering-approved replacement component automatically presented the same compliance risk as the original. In practice, that assumption can be misleading. From an engineering perspective, the components may be interchangeable. From a compliance perspective, they might not be.

A replacement connector might use a different plating process. An alternative cable assembly could contain a different plasticizer. A substitute component may incorporate a different solder finish, polymer formulation, or flame-retardant system. It may be that none of these changes affect electrical performance or reliability, yet each can alter the restricted-substance profile of the finished product.

The same principle applies to supplier changes that can remain invisible to the manufacturer. Suppliers could introduce new raw materials, modify formulations, qualify upstream suppliers, or change manufacturing processes without changing a component’s function or, in some cases, even its part number. A declaration that was accurate when issued might no longer describe the component being purchased today.

This changes the question manufacturers should be asking. Rather than asking, “Do we have a supplier declaration?” the better question is, “Can we demonstrate that our supporting evidence still describes the exact product currently entering production?”

Where compliance risk appears in practice

The JACOP findings provide a practical view of where physical-product risk can appear. Authorities identified elevated concentrations of lead and cadmium in solder joints, while restricted phthalates were commonly detected in soft PVC used for USB cables, power cords, and plugs. Restricted brominated flame retardants and hexavalent chromium were also identified in selected materials.

See the European Commission’s JACOP results for the laboratory and documentation findings.

These findings also highlight an important feature of RoHS: Maximum concentration limits apply at the level of the homogeneous material, not the finished product. A single solder joint, cable sleeve, coating, or plastic housing can determine whether an otherwise compliant product meets the applicable requirements. Directive 2011/65/EU (RoHS Recast) sets out the relevant framework.

The laboratory findings are therefore only part of the story. Regulators can compare test results with supplier documentation, technical files, and conformity records to determine whether the documented evidence accurately represents the physical product.

For quality professionals, this reinforces an important principle: Product conformity depends as much on controlling information and change as it does on controlling manufacturing processes.

A single material could also create obligations under several regulatory frameworks. A cable assembly, for example, might need to satisfy RoHS restrictions, REACH requirements, and the EU POPs regulation while also supporting SCIP (substances of concern in products) notifications or customer-specific reporting requirements.

Relevant frameworks include REACH Regulation (EC) No 1907/2006, EU POPs Regulation (EU) 2019/1021, and the ECHA Candidate List.

What manufacturers should do

The lesson from recent enforcement is not that supplier declarations have become unimportant. Rather, declarations should be treated as controlled compliance evidence that must remain connected to the product and its changes.

First, environmental compliance should become a formal checkpoint within engineering change control. Engineering changes, alternate components, supplier changes, and manufacturing transfers should trigger a compliance review rather than leaving compliance as a downstream documentation activity.

Procurement, engineering, quality, and compliance teams should share information rather than working independently, so that compliance becomes an integral part of product life cycle management rather than a periodic documentation exercise.

Second, organizations should strengthen traceability between supplier documentation, the bill of materials, the exact part number and revision, the manufacturing location, and the product configuration currently in production.

Third, risk-based testing can provide assurance where documentation alone isn’t enough. Testing every component would be impractical. But selective analytical testing can be valuable when qualifying new suppliers, approving second-source components, introducing manufacturing changes, or reviewing products containing historically higher-risk materials such as solder, soft PVC, and flame-retardant plastics.

Fourth, manufacturers should consider full material declarations (FMDs) and richer substance-level product data. A common information foundation can support multiple regulatory assessments instead of maintaining disconnected evidence for each regulation. The goal isn’t simply to collect more documents; it’s to build greater confidence that the information already held remains current and usable.

These developments also suggest that organizations should reconsider how they measure the effectiveness of their compliance programs. Historically, success was often measured by the number of declarations collected or the percentage of parts covered by documentation. Those metrics remain useful, but they don’t necessarily indicate whether the supporting information still reflects current production.

Four questions for a more resilient compliance system

Organizations can test the effectiveness of their compliance systems with four practical questions.

1. Can supplier documentation be traced to the exact part number, revision, and manufacturing location currently in production?

2. Do engineering and supplier changes automatically trigger a compliance review?

3. Are RoHS exemptions and other evolving regulatory requirements actively monitored?

4. If regulators tested the product tomorrow, would laboratory results support the information contained in the technical file?

Conclusion

Recent European enforcement suggests that the central compliance challenge is no longer simply whether a manufacturer has collected the required documentation. It’s whether the organization can demonstrate that its evidence still describes the product leaving the factory.

That requires change-control integration, traceability, current supplier and product data, full material declarations where appropriate, and risk-based verification. The same information discipline also matters in other highly regulated sectors, including pharmaceuticals, medical devices, and food, but the lesson is particularly clear for electronics manufacturers managing complex, rapidly changing component supply chains.

Suppliers change. Materials change. Manufacturing processes change. Regulations evolve. Therefore, a resilient compliance program must evolve with them.

The better question is no longer simply, “Do we have the required documentation?” It is, “How confident are we that our documentation still describes the product leaving the factory today?”

Organizations that can answer that question with confidence will be better prepared not only for regulatory scrutiny but also for increasingly complex global supply chains where product compliance depends as much on the quality of information as on the quality of the product itself.