Azerbaijan RoHS Technical Regulation: Consultation Open
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Azerbaijan RoHS Technical Regulation: Public Consultation Opens on Hazardous Substances in Electrical and Radioelectronic Products
Azerbaijan has moved a step closer to introducing its first national restriction on hazardous substances in electronics. A draft technical regulation, "On the Restriction of the Use of Certain Hazardous Substances in Electrical and Radioelectronic Products," has been published for public consultation, opening the door for manufacturers, importers and industry associations to comment before the text is finalised.
For companies selling electrical and electronic equipment (EEE) into Azerbaijan, this is an early warning signal rather than an immediate compliance deadline. But the direction of travel is clear: a substance restriction layer is being added to Azerbaijan's national conformity assessment system, and it is being built on familiar international foundations.
What Has Actually Happened and What Has Not
It is important to be precise about the regulatory status, because draft instruments are frequently reported as if they were already in force.
Item | Status |
Instrument type | National technical regulation (draft) |
Title | "On the Restriction of the Use of Certain Hazardous Substances in Electrical and Radioelectronic Products" |
Stage | Draft open for public consultation |
Legally binding today? | No |
Publishing authority | State Agency for Antimonopoly and Consumer Market Control under the President of the Republic of Azerbaijan |
Consultation opened | 14 April 2026 |
Route to becoming law | Approval by decision of the Cabinet of Ministers of the Republic of Azerbaijan |
The regulation is not yet enforceable. No certification body in Azerbaijan can currently require RoHS conformity under this instrument, and no product is currently non-compliant because of it. What exists is a draft that, once approved by the Cabinet of Ministers, would create binding obligations most likely following a defined transition period.
Where to Read the Draft Official Government Source
The draft and the comment submission form are hosted in the "Public hearing and discussion of draft technical regulations" subsection of the State Agency's official website:
Why Azerbaijan Is Doing This Now
The RoHS draft is not an isolated act. It sits inside a much broader national quality infrastructure programme. Azerbaijan's State Agency has been developing a package of national technical regulations covering non food consumer goods including low voltage electrical equipment safety, electromagnetic compatibility (EMC), machinery safety, and ecodesign and energy labelling for household appliances with each draft taken through the same public hearing process.
Read against that backdrop, the RoHS draft completes a recognisable regulatory triangle for electronics:
Electrical safety (low-voltage equipment technical regulation)
Electromagnetic compatibility (EMC technical regulation)
Substance restriction (this RoHS draft)
That is precisely the structure used in the EU (LVD + EMCD + RoHS) and in the Eurasian Economic Union (TR CU 004, TR CU 020, TR EAEU 037). Azerbaijan appears to be aligning its market access architecture with both blocs simultaneously a rational choice for a country that trades heavily with the EU, Türkiye, and EAEU states.
Scope of the Azerbaijan RoHS Technical Regulation
The title of the draft uses the phrase "electrical and radioelectronic products" the same terminology used in EAEU TR 037/2016, rather than the EU's "electrical and electronic equipment." That wording choice is a meaningful signal: it suggests the drafters worked from the Eurasian model, which uses a closed list of product categories rather than the EU's open-scope "catch all" approach.
Under the EAEU model, the categories typically captured are:
Household electrical appliances
Computers and connected devices
Telecommunications terminal equipment
Copiers and other electrical office equipment
Power tools (hand-held and portable)
Light sources and lighting equipment, including furniture-integrated lighting
Electronic musical instruments
Gaming and vending machines
Cash registers, ticket printers, card readers, ATMs and information kiosks
Cables, wires and cords rated at up to 500 V AC/DC (excluding fibre optic)
Electronic toys and children's electronic products
Electronic measuring instruments
Restricted Substances Expected Under the Azerbaijan RoHS Technical Regulation
The draft is expected to adopt the internationally harmonised ten substance list and maximum concentration values, which are identical across EU RoHS (Directive 2011/65/EU as amended by 2015/863) and EAEU TR 037/2016. Those baseline values are:
Restricted substance | Maximum concentration by weight in homogeneous material |
Lead (Pb) | 0.1% |
Mercury (Hg) | 0.1% |
Cadmium (Cd) | 0.01% |
Hexavalent chromium (Cr VI) | 0.1% |
Polybrominated biphenyls (PBB) | 0.1% |
Polybrominated diphenyl ethers (PBDE) | 0.1% |
Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% |
Butyl benzyl phthalate (BBP) | 0.1% |
Dibutyl phthalate (DBP) | 0.1% |
Diisobutyl phthalate (DIBP) | 0.1% |
Two cautions apply. First, the four phthalates (DEHP, BBP, DBP, DIBP) were added to EU RoHS later than the six original substances and are not restricted under EAEU TR 037/2016 so whether Azerbaijan restricts six substances or ten is a genuinely open question that the draft text will settle.
Second and this is the trap that catches experienced compliance teams exemptions do not travel automatically. Uzbekistan's recent RoHS regulation is the cautionary example: it adopted EU aligned limits but did not map across the EU's Annex III and Annex IV exemptions. An exemption that is valid in the EU today cannot be assumed valid in a new jurisdiction unless that jurisdiction has expressly adopted it. The Azerbaijani draft's exemption annex should therefore be read line by line, not skimmed.
What This Means for Manufacturers
If you place electrical or electronic products on the Azerbaijani market as a manufacturer, importer, brand owner or authorised representative here is the practical read.
1. Nothing is required of you today. This is a draft. There is no filing, no test report, no declaration and no certificate that is due right now under this instrument.
2. But your exposure is asymmetric. If Azerbaijan adopts the EU aligned ten substance list, the technical burden for most global manufacturers is low, because a product already compliant with EU RoHS will almost certainly meet the substance limits. The burden falls on documentation and conformity assessment, not on product redesign you will need Azerbaijan recognised evidence, not just an EU Declaration of Conformity.
3. The real risk sits in your supply chain, not your BOM. Companies that fail RoHS transitions rarely fail because a substance was present. They fail because a Tier 2 supplier could not produce a material declaration, or because a component was substituted without a new test report, or because full material declarations existed only for the EU market variant of a product.
4. Consultation is leverage. The comment window is the only point at which scope, exemptions and transition length are still movable. Manufacturers with narrow, technically justified exemption needs (industrial equipment, spare parts, legacy repair inventory) should say so on the record now not after the Cabinet of Ministers has signed.
5. Watch the local representative question. Regulations of this type routinely place obligations on the entity that places the product on the domestic market. If you sell into Azerbaijan through a distributor, confirm now who is contractually responsible for holding the technical file.
Certification Impact Summary
Compliance dimension | Expected impact | Confidence |
Product design / BOM | Low for EU RoHS compliant products; the substance limits are expected to be harmonised | Moderate pending scope confirmation |
Testing | Analytical testing (XRF screening plus wet chemistry / GC-MS for phthalates and Cr VI) at homogeneous material level | High |
Technical documentation | Full Material Declarations (FMDs) and supplier declarations across the BOM; new Azerbaijan specific technical file expected | High |
Conformity assessment route | Declaration of conformity and/or certification via an accredited body | Low |
Marking | Conformity mark under Azerbaijan's national conformity marking rules, following existing Cabinet of Ministers rules on the form and use of the conformity mark | Moderate |
Testing laboratory | Testing expected to require an accredited laboratory recognised under Azerbaijan's accreditation law | Moderate |
Exemptions | Must be claimed from Azerbaijan's own annex EU exemptions are not presumed to carry over | High |
Existing certificates | EU RoHS DoC and EAC RoHS declarations will not substitute for national conformity; expect to re-document | Moderate |
The single most important line in that table is the last one. Do not assume mutual recognition. Azerbaijan is building a national conformity system, and national systems generally require national evidence.
Timeline and Required Actions
Regulatory timeline
Date | Milestone | Status |
14 April 2026 | Draft technical regulation published for public consultation | Confirmed as draft stage |
Public consultation and stakeholder hearing period closes | Date not published in available sources | |
Post-consultation | Comments analysed; draft agreed with relevant state bodies | Expected |
Submission to and approval by the Cabinet of Ministers | Not yet occurred | |
Official publication and entry into force | Not yet occurred | |
End of transition period / mandatory compliance | Not yet defined |
Required actions by phase
Now (during the consultation window)
Download the Azerbaijani draft (Word or PDF) from the State Agency portal and have it professionally translated. Do not work from a summary.
Map the draft's scope article against your Azerbaijan product portfolio, SKU by SKU, and flag anything ambiguous.
Compare the draft's exemption annex against every EU RoHS exemption you currently rely on. Any gap is a redesign risk.
Submit comments through the portal's comment function individually or through your industry association on scope, exemptions and transition length.
Once the final text is approved
Confirm the conformity assessment route (declaration vs. certification) and the accepted testing laboratories.
Collect Full Material Declarations from all suppliers for products in scope, at homogeneous material level.
Commission RoHS analytical testing where supplier documentation is incomplete or unverified.
Build the Azerbaijan technical file and issue the required declaration or apply for the certificate.
Verify conformity marking and labelling requirements before the transition period closes.
Ongoing
Add Azerbaijan to your change control process: any component substitution after certification is a potential compliance breach unless re-evaluated.
The Bigger Picture: RoHS Is Going Global
Azerbaijan's draft lands in a year of unusually dense RoHS activity worldwide. Uzbekistan has approved its first RoHS technical regulation. Brazil has proposed a self-declaration-based RoHS regime built on a national register of EEE. Vietnam's mandatory RoHS technical regulation remains unfinalised, with interim substance-disclosure obligations filling the gap. The EU continues to revise its own exemption framework.
The strategic implication for manufacturers is that RoHS is no longer a single-market compliance exercise with one Declaration of Conformity. It is becoming a portfolio of jurisdiction-specific declarations, each with its own scope, its own exemption list, and its own evidentiary requirements even where the underlying substance limits are identical. Companies that centralise material data now, rather than assembling it market by market under deadline pressure, will absorb these new regimes at a fraction of the cost.
Frequently Asked Questions
Is the Azerbaijan RoHS technical regulation in force? No. It is a draft published for public consultation. It becomes binding only after approval by the Cabinet of Ministers and official publication, and it would normally carry a transition period after that.
Will my EU RoHS Declaration of Conformity be accepted in Azerbaijan? It should not be assumed to be. Azerbaijan is establishing a national conformity assessment framework. Your EU test data will very likely support your Azerbaijani submission, but a national declaration or certificate is expected to be required in its own right.
Do EU RoHS exemptions apply in Azerbaijan? Not automatically. Exemptions apply only if Azerbaijan's own text adopts them. This is a well documented failure point in other jurisdictions that adopted EU aligned RoHS limits without adopting the EU exemption annexes.
How can I comment on the draft? Through the "Rəy, irad və təklifini bildir" (submit opinion, remark and proposal) function attached to the draft on the State Agency for Antimonopoly and Consumer Market Control's public consultation page.
