Guess I'm replying a little late here, but better late than never! First off, it really is impossible to make a generic statement that covers every product you make unless every product you make has the exact same composition. Second, you have to consider if you are choosing the materials or is the customer? If the customer is doing the material selection, you have no power over whether they meet ROHS or REACH. We are a job shop and use about 99% customer selected materials, therefore, our ROHS and REACH declarations are along these lines:
"To the best of our knowledge the products listed on this document do not contain any of the currently listed SVHC in concentrations of 0.1% or above. The absence of SVHC has not been verified by analysis or tests and is declared based on the information available to us from our raw material suppliers. It is the responsibility of the recipient of our products to ensure that applicable rules and legislation are observed."
When our customer ask if we are ROHS and REACH compliant, I just say "yes". When they ask for a declaration, I ask for which part number(s).
Hope this helps.