Saudi Arabia Notifies WTO of Proposed Amendments to RoHS Regulation

On July 21, 2025, Saudi Arabia notified the World Trade Organization (WTO) of proposed amendments to its “Technical Regulation on the Restriction of Hazardous Substances in Electrical and Electronic Equipment for Fiscal Year 2021” (RoHS Regulation), inviting public comments for a 30-day period. The amended regulation will take effect 180 days after its publication in the official gazette, followed by a 365-day transition period.

Key Differences Between the Current Regulation and the Proposed Amendments

1. Expansion of Restricted Substances and Covered Products

In addition to the six substances currently regulated, four types of phthalates will be added, each with a maximum concentration limit of 0.1 percent—aligning the regulation with the EU RoHS Directive.
The scope of covered products will be expanded: new categories such as consumer equipment and automatic dispensers will be added, and household appliances will be further classified into small and large types.

2. Clarification of Obligations by Economic Operator

Whereas the current regulation broadly defines “supplier obligations,” the proposed amendments specify responsibilities for each economic operator: manufacturer, authorized representative, importer, and distributor.

• Manufacturer obligations:

• • Conduct conformity assessment procedures and issue a Declaration of Conformity.
  • Retain the Declaration of Conformity and related technical documentation (Technical File) for ten years.

• Importer obligations:

• • Verify that the manufacturer has conducted conformity assessment procedures and issue a Declaration of Conformity.

3. Expansion of General and Labeling Requirements

In addition to basic requirements such as safe assembly and packaging, the proposed amendments include detailed labeling requirements.
Product labeling must be in Arabic and include: product details, traceability numbers, manufacturer/importer information, safety instructions and symbols, and other information specified in relevant regulations.

4. Updates to Conformity Assessment Procedures and Technical Documentation

• The conformity assessment procedure will shift from the current Type a1 to the new Type S, requiring a Supplier’s Declaration of Conformity.
• Technical documentation must include, at minimum: the manufacturer/importer’s Declaration of Conformity, risk assessment documents, product overview, and results of the conformity assessment.
• Documentation must be prepared in Arabic; if this is not feasible, a certified translation may be submitted.

Related Links
WTO Notification:
https://eping.wto.org/en/Search/Index?countryIds=C682&viewData=G%2FTBT%2FN%2FSAU%2F1166%2FCorr.1%2FAdd.1

Technical Regulation (Arabic):
Document 1:
https://members.wto.org/crnattachments/2025/TBT/SAU/modification/25_04719_00_x.pdf

Document 2:
https://members.wto.org/crnattachments/2025/TBT/SAU/modification/25_04719_01_x.pdf