RoHS vs REACH: Understanding the Two EU Chemical Regulations That Affect Your Products

Ask a product designer what RoHS and REACH are and they'll probably nod confidently. Ask them to explain the difference and things get murky fast. Both regulations deal with hazardous substances. Both apply to the EU. Both have acronyms that sound like they belong in the same sentence. And both can land you in serious trouble if you ignore them.

But they are not the same thing, and mixing them up — or assuming compliance with one covers the other — is a mistake that trips up companies every year.

This article breaks down what each regulation actually does, who it applies to, where they overlap, and what you actually need to do to stay compliant with both.

What Is RoHS?

RoHS stands for Restriction of Hazardous Substances. The current version — often called RoHS 3 — is EU Directive 2011/65/EU, amended by Directive 2015/863/EU.

The core idea is simple: certain hazardous substances are banned above specific concentration limits in electrical and electronic equipment (EEE) sold in the EU. If your product falls under RoHS scope, those substances cannot exceed the maximum permitted concentrations (MPCs) in homogeneous materials.

The restricted substances under RoHS are:

• Lead (Pb) — max 0.1% by weight
• Mercury (Hg) — max 0.1%
• Cadmium (Cd) — max 0.01%
• Hexavalent chromium (Cr VI) — max 0.1%
• Polybrominated biphenyls (PBB) — max 0.1%
• Polybrominated diphenyl ethers (PBDE) — max 0.1%
• Bis(2-ethylhexyl) phthalate (DEHP) — max 0.1%
• Butyl benzyl phthalate (BBP) — max 0.1%
• Dibutyl phthalate (DBP) — max 0.1%
• Diisobutyl phthalate (DIBP) — max 0.1%

The last four (the phthalates) were added more recently and caught a lot of manufacturers off guard — particularly those who assumed their existing RoHS compliance still held after 2019.

Who Does RoHS Apply To?

RoHS applies to manufacturers, importers, and distributors of electrical and electronic equipment placed on the EU market. If your product plugs in, runs on batteries, or generates an electromagnetic field, there's a decent chance RoHS applies to it.

Categories include consumer electronics, IT and telecommunications equipment, lighting, large and small household appliances, power tools, medical devices, monitoring and control instruments, and automatic dispensers.

To demonstrate compliance, manufacturers must prepare a technical file, issue a Declaration of Conformity, and affix the CE marking. The compliance burden sits primarily with whoever places the product on the EU market.

What Is REACH?

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It's EU Regulation (EC) No 1907/2006, and compared to RoHS, it's a significantly larger piece of legislation — REACH is one of the most complex chemical regulations in the world.

While RoHS says "these specific substances are banned in these specific products," REACH takes a broader approach: it regulates chemicals across their entire lifecycle, from manufacture and import through to use and disposal.

The parts of REACH most product companies deal with are:

Substances of Very High Concern (SVHC): REACH maintains a Candidate List of substances with properties like carcinogenicity, reproductive toxicity, or persistence in the environment. If an article you sell contains an SVHC above 0.1% by weight of the article, you have notification and communication obligations. The Candidate List currently contains over 240 substances and keeps growing.

Authorisation: Some SVHCs are placed on the Authorisation List (Annex XIV). Companies that want to continue using these substances must apply for authorisation from the European Chemicals Agency (ECHA) — and there's no guarantee they'll get it.

Restriction: Annex XVII of REACH lists substances with specific restrictions on manufacture, use, or placing on the market. Some RoHS substances are also restricted under REACH, creating overlap.

Who Does REACH Apply To?

This is where things get more complex than RoHS. REACH obligations depend heavily on your role in the supply chain:

• Manufacturers and importers of chemicals — must register substances with ECHA above certain tonnage thresholds
• Downstream users — companies that use chemicals in formulations or processes have their own obligations
• Producers and importers of articles — if your finished product contains SVHCs above 0.1% by weight, you must notify ECHA and inform your customers and consumers on request

That last point is the one most product companies need to pay attention to. If you're selling physical goods into the EU — whether that's electronics, furniture, textiles, toys, or anything in between — REACH's SVHC obligations likely apply to you.

The Key Differences

Here's where people get confused. Both regulations deal with hazardous substances. Both require action before you sell in the EU. But they operate very differently.

The fundamental difference: RoHS tells you what you cannot put in a product. REACH tells you what you must disclose and manage across the entire supply chain, and in some cases requires authorisation before you can even use certain substances.

How They Interact

The overlap between RoHS and REACH is real, and it creates some genuine complexity.

Several substances restricted under RoHS are also on the REACH Candidate List or Annex XVII. Lead, for example, is restricted under RoHS for electronics — but it also appears in REACH contexts. If you have a component with lead solder that's exempt from RoHS (there are specific exemptions), you still need to assess whether REACH SVHC communication obligations apply.

Similarly, phthalates appear in both frameworks. REACH restrictions on certain phthalates in consumer articles were actually a precursor to those same phthalates being added to the RoHS restricted list.

The practical implication: you cannot assume that RoHS compliance means REACH compliance, or vice versa. They need to be assessed separately.

What You Actually Need to Do

For RoHS Compliance

1. Determine if your product is in scope. Check whether it qualifies as electrical or electronic equipment under the directive categories.
2. Map your materials. Work with your supply chain to understand the material composition of every homogeneous material in your product. This usually means requesting declarations from suppliers and potentially commissioning lab testing.
3. Check against the restricted substance list. Verify that no restricted substance exceeds the maximum permitted concentration in any homogeneous material.
4. Document everything. Prepare a technical file with your testing data, supplier declarations, and risk assessment. Keep it for ten years.
5. Issue a Declaration of Conformity and apply CE marking. This is the formal declaration that your product meets RoHS requirements. Make sure your product labeling also meets the requirements of your target markets.

For REACH Compliance

1. Know your role in the supply chain. Whether you're a manufacturer, importer, or downstream user determines your specific obligations.
2. Monitor the SVHC Candidate List. ECHA updates it at least twice a year. Set up alerts so you know when new substances are added. A substance that wasn't an issue last year might be on the list today.
3. Check your articles for SVHCs. If any SVHC is present above 0.1% by weight of the article, you need to notify ECHA (for articles imported or manufactured in the EU) and communicate the substance name to your customers and to consumers on request within 45 days.
4. Check Annex XVII restrictions. Beyond SVHCs, make sure none of the specific use restrictions apply to your product or the way you're using it.
5. Check the Authorisation List. If you're using a substance on Annex XIV in an industrial process, check whether it requires authorisation — and whether you have it.

The Practical Overlap

For most product companies — especially in electronics — the workflow looks like this:

• Run RoHS compliance as part of your product development process, requiring supplier declarations and doing spot testing
• Separately, query your supply chain for SVHC presence in articles and stay current with Candidate List updates
• Maintain separate documentation for each — they have different record-keeping requirements and different audiences

Large electronics manufacturers typically use supply chain management software that tracks both simultaneously. If you're smaller, at minimum you need a reliable supplier communication process and a calendar reminder to check the ECHA Candidate List updates.

Common Mistakes to Avoid

Treating them as one regulation. They're not. RoHS compliance does not satisfy REACH obligations, and REACH SVHC communication does not make you RoHS compliant.

Ignoring the SVHC Candidate List updates. New substances are added regularly. A product that was REACH-clean two years ago may have an obligation today because a new SVHC was added that's present in one of your components.

Forgetting the phthalates. The four phthalates added to RoHS in 2019 catch people out because they're common plasticisers in cables, housings, and packaging materials. Many manufacturers discovered non-compliance only after the deadline passed.

Assuming exemptions are permanent. RoHS exemptions have expiry dates and must be renewed. If you're relying on an exemption, track its status — some have lapsed and left companies scrambling.

Not flowing REACH obligations down the supply chain. If you import a finished product, you're the importer of record and the REACH obligations are yours. Make sure your upstream suppliers can actually provide the SVHC data you need.

The Bottom Line

RoHS and REACH are complementary regulations that tackle the same underlying problem — hazardous substances in products — but from very different angles. RoHS is narrower in scope (electronics only) but has clear, hard limits. REACH is broader and more dynamic, with an evolving list of substances and a supply chain communication framework that runs through your entire business.

If you make or sell electronics in the EU, you almost certainly need to comply with both. If you sell non-electronic products, REACH still applies to you even if RoHS doesn't. And if you're anywhere in a supply chain that feeds into EU markets, understanding your REACH obligations is not optional.

Start by knowing which regulation applies to your specific product and role, then build the supplier communication and documentation processes to back it up. Both frameworks reward companies that treat compliance as a supply chain management discipline rather than a one-time checkbox.

References

1. RoHS Directive 2011/65/EU — EUR-Lex
2. Directive 2015/863/EU amending RoHS (adding phthalates) — EUR-Lex
3. REACH Regulation (EC) No 1907/2006 — EUR-Lex
4. SVHC Candidate List — European Chemicals Agency (ECHA)
5. Authorisation List (Annex XIV) — ECHA
6. Restriction List (Annex XVII) — ECHA
7. European Commission RoHS guidance — European Commission
8. REACH guidance for articles importers — ECHA