ESPR, REACH, and RoHS can all require material and substance data, but each uses a different legal test. ESPR can set product-group ecodesign performance and information requirements, including lifecycle information on substances of concern and Digital Product Passport fields. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulates substances on their own, in mixtures, and in articles through registration, evaluation, authorisation, restrictions, and supply-chain communication. RoHS (Restriction of Hazardous Substances) restricts listed substances in electrical and electronic equipment in each , subject to scope exclusions and time-limited exemptions. A supplier declaration may support more than one review, but it does not prove compliance with all three.
Comparison matrix
ESPR vs REACH and RoHS: ecodesign, DPP, and substance-control comparison
Use these rows to separate ESPR sustainability and information duties from chemical or hazardous-substance controls, and to identify where DPP data may carry substance evidence without changing REACH or RoHS scope.
ESPR is the sustainability and product-information column: product-group delegated acts may set performance requirements, information requirements, DPP data, conformity documentation, and market-surveillance evidence.
Second framework
REACH and RoHS
REACH controls chemicals across substances, mixtures, and articles; RoHS sets product-specific hazardous-substance restrictions for electrical and electronic equipment. Their triggers, thresholds, exemptions, actors, and evidence differ.
ESPR vs REACH and RoHS: ecodesign, DPP, and substance-control comparison
ESPR targets the environmental sustainability of products placed on the EU market through product-group ecodesign requirements. The Commission overview describes ESPR as extending ecodesign beyond energy-related products and improving circularity, energy performance, recyclability, and durability.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, technical documentation, declarations of conformity, corrective action, market surveillance, and penalties.
performance requirements or information requirements, or both
Commission overview explaining that ESPR extends ecodesign beyond energy-related products and aims to improve circularity, energy performance, recyclability, and durability.
improving their circularity, energy performance, recyclability and durability
REACH applies broadly to the manufacture, placing on the market, and use of substances on their own, in mixtures, or in articles, subject to its titles and exemptions. RoHS applies to electrical and electronic equipment within its categories and definitions, with exclusions in Article 2 and exemptions in Annexes III and IV.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Do not use a REACH or RoHS substance review as proof that ESPR ecodesign requirements are met, and do not use ESPR sustainability evidence as proof of a REACH or RoHS result without a separate source.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
ESPR evidence normally sits with product compliance, engineering, sustainability, supply-chain data owners, and the economic operator placing the product on the EU market or putting it into service when a delegated act applies.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH duties can fall on manufacturers, importers, downstream users, distributors, producers or importers of articles, and suppliers of articles, depending on the activity and substance. Under RoHS, manufacturers establish conformity; importers and distributors have verification and corrective-action duties; an importer or distributor can assume manufacturer obligations by selling under its own name or modifying equipment in a way that may affect compliance.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Map the legal entity and role for each regime. Do not assign an Article 33 REACH communication, a RoHS declaration, or an ESPR DPP field to a generic supplier-data owner without identifying who has the legal duty.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
ESPR action starts when a product group is covered by an ESPR delegated act or related ESPR requirement. The delegated act determines the specific product parameters, methods, DPP data, and conformity evidence to prepare.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH triggers depend on the activity. One article-specific example is Article 33: a supplier of an article containing a Candidate List substance above 0.1% weight by weight must provide the recipient with sufficient available information for safe use, including at least the substance name; consumers receive corresponding information on request within 45 days. RoHS Article 4 instead tests in each of covered electrical and electronic equipment.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Use the ESPR delegated act for the ESPR trigger, the applicable REACH title or Candidate List entry for the REACH trigger, and the RoHS category, , restricted substance, and exemption for the RoHS trigger.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
ESPR delegated acts may set performance requirements, information requirements, or both. The regulation links those requirements to product parameters such as durability, repairability, energy efficiency, recyclability, carbon and environmental footprints, and substances-of-concern information.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Commission overview explaining that ESPR extends ecodesign beyond energy-related products and aims to improve circularity, energy performance, recyclability, and durability.
improving their circularity, energy performance, recyclability and durability
REACH may require registration, supply-chain communication, authorisation for listed uses, compliance with Annex XVII restrictions, or article notifications, depending on the facts. RoHS generally limits lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP to 0.1% by weight in homogeneous materials and cadmium to 0.01%, subject to exclusions and Annex III or IV exemptions.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Build separate control maps. ESPR needs the product-group requirement and DPP or conformity output; REACH needs the applicable substance, use, article, list, and actor test; RoHS needs the equipment category, material-level result, and current exemption analysis.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
ESPR evidence should connect the applicable delegated act, technical documentation, measurements against ecodesign requirements, information provided under information requirements, declaration of conformity, DPP fields, and market-surveillance response process.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH evidence can include registrations, safety data sheets, exposure information, authorisation or restriction analysis, Candidate List status, Article 33 communications, supplier records, and applicable article notifications. RoHS manufacturers need technical documentation, conformity assessment, an EU declaration of conformity, CE marking, series-production controls, and records of non-conforming equipment and corrective action.
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Create a crosswalk field by field: source, product scope, data owner, date/version, public or restricted DPP access, and whether the evidence supports ESPR, REACH, RoHS, or only an internal material review.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
ESPR timing depends on the relevant delegated act and product group. DPP design guidance repeatedly points teams back to the specific delegated act for information requirements, access, and update expectations.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, technical documentation, declarations of conformity, corrective action, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH Candidate List duties can change when ECHA adds a substance: Article 33 communication applies once the listing and concentration conditions are met, and a consumer request must be answered free of charge within 45 days. RoHS exemption expiry and renewal dates vary by entry and equipment category, so teams must use the current consolidated directive and the latest amending delegated acts rather than a static exemption list.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Track ESPR act dates, Candidate List changes, REACH authorisation or restriction dates, and RoHS exemption dates in separate calendars. Link a reminder only to the affected substance, article or , equipment category, legal entity, and evidence owner.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
ESPR assurance runs through technical documentation, declarations of conformity, conformity marking where required, market surveillance, corrective action, and Member State penalties for infringements.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
REACH and RoHS are enforced through their own authority and Member State systems. RoHS requires economic operators that know or have reason to believe equipment is non-compliant to prevent or stop market availability as applicable, take corrective measures, and inform authorities where the equipment presents a risk. Penalty amounts and procedures remain matters for applicable Member State law.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
For each review, ask whether the product meets the ESPR act, whether the REACH substance or article duties are satisfied, and whether every covered RoHS complies or has a current exemption. Route non-compliance through the correct regime.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Use ESPR when the decision concerns product sustainability performance, product information, DPP data, conformity documentation, public or restricted product information access, or market surveillance under an ESPR delegated act.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Commission source describing the DPP as an ESPR mechanism to store and share product sustainability, durability, environmental, instruction, and conformity information.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
Use REACH for the applicable chemical registration, communication, authorisation, or restriction question. Use RoHS for in covered electrical and electronic equipment at homogeneous-material level. Neither conclusion establishes that an ESPR product-group sustainability requirement is met.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
If both lanes touch the same product data, publish only the claim each source supports: ESPR for ecodesign/DPP information, REACH/RoHS for substance-control status, and a crosswalk for shared fields.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
ESPR can require tracking and communication of substances-of-concern information as sustainability information across a product life cycle, including support for decontamination and recovery when products become waste.
ESPR explains that chemical-safety restrictions remain primarily addressed by other Union chemicals law while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
ESPR itself says it should not restrict substances primarily for chemical-safety reasons because other Union chemicals law addresses that function. RoHS remains a separate hazardous-substance restriction regime for electrical and electronic equipment.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Treat ESPR substance fields as sustainability and lifecycle information unless a source shows a product-specific restriction; keep chemical-safety restriction decisions in the REACH/RoHS lane.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Limited to cited sources comparator: cited source material cites REACH by title as Registration, Evaluation, Authorisation and Restriction of Chemicals and as existing chemicals law ESPR should take into account.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS legal source for hazardous-substance restrictions in electrical and electronic equipment; the applicable Annex II thresholds and Annex III or IV exemptions require the current consolidated text and amendment acts for the specific equipment and homogeneous material.
restriction of the use of certain hazardous substances
Scope boundary
ESPR
ESPR targets the environmental sustainability of products placed on the EU market through product-group ecodesign requirements. The Commission overview describes ESPR as extending ecodesign beyond energy-related products and improving circularity, energy performance, recyclability, and durability.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, technical documentation, declarations of conformity, corrective action, market surveillance, and penalties.
performance requirements or information requirements, or both
Commission overview explaining that ESPR extends ecodesign beyond energy-related products and aims to improve circularity, energy performance, recyclability, and durability.
improving their circularity, energy performance, recyclability and durability
REACH and RoHS
REACH applies broadly to the manufacture, placing on the market, and use of substances on their own, in mixtures, or in articles, subject to its titles and exemptions. RoHS applies to electrical and electronic equipment within its categories and definitions, with exclusions in Article 2 and exemptions in Annexes III and IV.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
Do not use a REACH or RoHS substance review as proof that ESPR ecodesign requirements are met, and do not use ESPR sustainability evidence as proof of a REACH or RoHS result without a separate source.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Covered actors
ESPR
ESPR evidence normally sits with product compliance, engineering, sustainability, supply-chain data owners, and the economic operator placing the product on the EU market or putting it into service when a delegated act applies.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH and RoHS
REACH duties can fall on manufacturers, importers, downstream users, distributors, producers or importers of articles, and suppliers of articles, depending on the activity and substance. Under RoHS, manufacturers establish conformity; importers and distributors have verification and corrective-action duties; an importer or distributor can assume manufacturer obligations by selling under its own name or modifying equipment in a way that may affect compliance.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
Map the legal entity and role for each regime. Do not assign an Article 33 REACH communication, a RoHS declaration, or an ESPR DPP field to a generic supplier-data owner without identifying who has the legal duty.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
Global digital sustainable product passport
Trigger
ESPR
ESPR action starts when a product group is covered by an ESPR delegated act or related ESPR requirement. The delegated act determines the specific product parameters, methods, DPP data, and conformity evidence to prepare.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH and RoHS
REACH triggers depend on the activity. One article-specific example is Article 33: a supplier of an article containing a Candidate List substance above 0.1% weight by weight must provide the recipient with sufficient available information for safe use, including at least the substance name; consumers receive corresponding information on request within 45 days. RoHS Article 4 instead tests in each of covered electrical and electronic equipment.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
Use the ESPR delegated act for the ESPR trigger, the applicable REACH title or Candidate List entry for the REACH trigger, and the RoHS category, , restricted substance, and exemption for the RoHS trigger.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Core obligations
ESPR
ESPR delegated acts may set performance requirements, information requirements, or both. The regulation links those requirements to product parameters such as durability, repairability, energy efficiency, recyclability, carbon and environmental footprints, and substances-of-concern information.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Commission overview explaining that ESPR extends ecodesign beyond energy-related products and aims to improve circularity, energy performance, recyclability, and durability.
improving their circularity, energy performance, recyclability and durability
REACH and RoHS
REACH may require registration, supply-chain communication, authorisation for listed uses, compliance with Annex XVII restrictions, or article notifications, depending on the facts. RoHS generally limits lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP to 0.1% by weight in homogeneous materials and cadmium to 0.01%, subject to exclusions and Annex III or IV exemptions.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
Build separate control maps. ESPR needs the product-group requirement and DPP or conformity output; REACH needs the applicable substance, use, article, list, and actor test; RoHS needs the equipment category, material-level result, and current exemption analysis.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Evidence record
ESPR
ESPR evidence should connect the applicable delegated act, technical documentation, measurements against ecodesign requirements, information provided under information requirements, declaration of conformity, DPP fields, and market-surveillance response process.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH and RoHS
REACH evidence can include registrations, safety data sheets, exposure information, authorisation or restriction analysis, Candidate List status, Article 33 communications, supplier records, and applicable article notifications. RoHS manufacturers need technical documentation, conformity assessment, an EU declaration of conformity, CE marking, series-production controls, and records of non-conforming equipment and corrective action.
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
Create a crosswalk field by field: source, product scope, data owner, date/version, public or restricted DPP access, and whether the evidence supports ESPR, REACH, RoHS, or only an internal material review.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
Global digital sustainable product passport
Timing and deadlines
ESPR
ESPR timing depends on the relevant delegated act and product group. DPP design guidance repeatedly points teams back to the specific delegated act for information requirements, access, and update expectations.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, technical documentation, declarations of conformity, corrective action, market surveillance, and penalties.
performance requirements or information requirements, or both
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH and RoHS
REACH Candidate List duties can change when ECHA adds a substance: Article 33 communication applies once the listing and concentration conditions are met, and a consumer request must be answered free of charge within 45 days. RoHS exemption expiry and renewal dates vary by entry and equipment category, so teams must use the current consolidated directive and the latest amending delegated acts rather than a static exemption list.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
Track ESPR act dates, Candidate List changes, REACH authorisation or restriction dates, and RoHS exemption dates in separate calendars. Link a reminder only to the affected substance, article or , equipment category, legal entity, and evidence owner.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
Enforcement
ESPR
ESPR assurance runs through technical documentation, declarations of conformity, conformity marking where required, market surveillance, corrective action, and Member State penalties for infringements.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
REACH and RoHS
REACH and RoHS are enforced through their own authority and Member State systems. RoHS requires economic operators that know or have reason to believe equipment is non-compliant to prevent or stop market availability as applicable, take corrective measures, and inform authorities where the equipment presents a risk. Penalty amounts and procedures remain matters for applicable Member State law.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
For each review, ask whether the product meets the ESPR act, whether the REACH substance or article duties are satisfied, and whether every covered RoHS complies or has a current exemption. Route non-compliance through the correct regime.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Practical decision rule
ESPR
Use ESPR when the decision concerns product sustainability performance, product information, DPP data, conformity documentation, public or restricted product information access, or market surveillance under an ESPR delegated act.
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
performance requirements or information requirements, or both
Commission source describing the DPP as an ESPR mechanism to store and share product sustainability, durability, environmental, instruction, and conformity information.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
REACH and RoHS
Use REACH for the applicable chemical registration, communication, authorisation, or restriction question. Use RoHS for in covered electrical and electronic equipment at homogeneous-material level. Neither conclusion establishes that an ESPR product-group sustainability requirement is met.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
If both lanes touch the same product data, publish only the claim each source supports: ESPR for ecodesign/DPP information, REACH/RoHS for substance-control status, and a crosswalk for shared fields.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Substance-information and chemical-safety boundary
ESPR
ESPR can require tracking and communication of substances-of-concern information as sustainability information across a product life cycle, including support for decontamination and recovery when products become waste.
ESPR explains that chemical-safety restrictions remain primarily addressed by other Union chemicals law while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
REACH and RoHS
ESPR itself says it should not restrict substances primarily for chemical-safety reasons because other Union chemicals law addresses that function. RoHS remains a separate hazardous-substance restriction regime for electrical and electronic equipment.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
Operational implication
Treat ESPR substance fields as sustainability and lifecycle information unless a source shows a product-specific restriction; keep chemical-safety restriction decisions in the REACH/RoHS lane.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
should not provide for the restriction of substances based primarily on chemical safety
Limited to cited sources comparator: cited source material cites REACH by title as Registration, Evaluation, Authorisation and Restriction of Chemicals and as existing chemicals law ESPR should take into account.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS legal source for hazardous-substance restrictions in electrical and electronic equipment; the applicable Annex II thresholds and Annex III or IV exemptions require the current consolidated text and amendment acts for the specific equipment and homogeneous material.
restriction of the use of certain hazardous substances
Practical decision rule
How should teams separate ESPR from REACH and RoHS?
Start with the regulatory purpose: ESPR for ecodesign, sustainability, information, DPP, conformity, and market-surveillance evidence; REACH/RoHS for separate substance-control questions.
Use the ESPR delegated act to define product-group sustainability and DPP requirements; use the current REACH lists and annexes for the chemical or article test and the current RoHS text and exemption acts for each .
Reuse supplier or material evidence only field by field, with a source, product scope, owner, version date, and statement of whether the evidence supports ESPR, REACH, RoHS, or more than one lane.
Primary source for product-group delegated acts, performance and information requirements, DPPs, conformity, market surveillance, and the boundary between ESPR substances-of-concern information and chemical-safety restrictions.
performance requirements or information requirements, or both
Commission source describing the DPP as an ESPR mechanism to store and share product sustainability, durability, environmental, instruction, and conformity information.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
restriction of the use of certain hazardous substances
1
Section 1
The substance tests are not interchangeable
Start with the legal object. ESPR asks what the applicable product-group act requires for sustainability performance, information, conformity, or a DPP. REACH may test a substance, mixture, use, or article and the actor's role. RoHS tests each in covered electrical and electronic equipment against Annex II, subject to the relevant exclusions and exemptions.
The common 0.1% figure can mislead. Under REACH Article 33 it is the threshold for a Candidate List substance in an article. Under RoHS, 0.1% is the maximum concentration for most Annex II substances in a , while cadmium is 0.01%. ESPR can require information on substances of concern under its own definition and delegated-act rules; that does not convert the REACH or RoHS threshold into an ESPR limit.
For REACH Article 33, record the Candidate List entry date, concentration at article level, supplier and recipient, safe-use information, and any consumer request and 45-day response.
For RoHS, record the equipment category, each , laboratory or supplier evidence, restricted-substance result, exemption entry and expiry status, technical documentation, declaration, and CE marking.
For ESPR, record the applicable delegated act, its substances-of-concern definition or information requirement, the product or component level, access rights, and the DPP or other disclosure destination.
Articles 2, 4 and 7 and Annex II establish equipment scope, the homogeneous-material restriction, manufacturer evidence duties, and maximum concentrations; Annexes III and IV contain exemptions that must be checked in their current form.
restriction of the use of certain hazardous substances
2
Section 2
Where the same evidence may matter twice
Supplier material declarations, substances-of-concern fields, European Chemicals Agency (ECHA) or its substances-in-articles database (SCIP) references, recycled-content data, conformity documents, and repairability information where a cited ESPR or DPP source supports the field may all sit near the same product record, but each field still needs a cited purpose.
For DPP design, the practical control is a crosswalk: one row per data element, with the source requiring it, the product group, the owner, the access level, the update trigger, and whether it supports ESPR, REACH, RoHS, or only internal due diligence.
Use DPP fields for ESPR information requirements when the applicable delegated act requires them.
Link substance evidence into the DPP only when the ESPR delegated act or another cited source supports that publication or restricted-access use.
Keep non-public supplier chemistry files out of public DPP views unless the source and access model support disclosure.
Commission source describing the DPP as an ESPR mechanism to store and share product sustainability, durability, environmental, instruction, and conformity information.
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
consult the delegated act for the specific product group
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
Global digital sustainable product passport
Recommended next step
Separate ESPR, DPP, and substance evidence
This ESPR comparison helps map sustainability requirements, DPP fields, and separately sourced substance evidence before product teams publish or reuse compliance claims.
Primary source for product-group delegated acts, performance and information requirements, DPPs, conformity, market surveillance, and the chemical-safety boundary.
Primary source for ESPR product-group requirements, substances-of-concern information, DPP duties, and the chemical-safety boundary.
ESPR source explaining that chemical safety restrictions remain primarily addressed by other Union chemicals law, while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
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Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, market surveillance, and penalties.
ESPR explains that chemical-safety restrictions remain primarily addressed by other Union chemicals law while ESPR can set sustainability-related performance and information requirements, including substances-of-concern tracking.
Primary source for product-group delegated acts, performance and information requirements, DPPs, conformity, market surveillance, and the boundary between ESPR substances-of-concern information and chemical-safety restrictions.
"performance requirements or information requirements, or both"
More quoted passages
"should not provide for the restriction of substances based primarily on chemical safety"
Primary RoHS source for electrical and electronic equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, CE marking, and exemptions.
Articles 2, 4 and 7 and Annex II establish equipment scope, the homogeneous-material restriction, manufacturer evidence duties, and maximum concentrations; Annexes III and IV contain exemptions that must be checked in their current form.
Primary RoHS text for equipment scope, homogeneous-material restrictions, Annex II concentrations, actor duties, conformity evidence, and exemptions; current amendments must be checked for the specific case.
Show 1 more
Primary RoHS legal source for hazardous-substance restrictions in electrical and electronic equipment; the applicable Annex II thresholds and Annex III or IV exemptions require the current consolidated text and amendment acts for the specific equipment and homogeneous material.
"restriction of the use of certain hazardous substances"
Primary REACH source for substance, mixture, use, article, registration, authorisation, restriction, and Article 33 supply-chain communication duties.
Article 33 establishes the Candidate List article-communication threshold, minimum information, consumer-request right, and 45-day response period.
Primary REACH text for substance, mixture, article, actor, registration, communication, authorisation, and restriction rules; current lists and annexes must be checked for the specific case.
Show 1 more
Limited to cited sources comparator: cited source material cites REACH by title as Registration, Evaluation, Authorisation and Restriction of Chemicals and as existing chemicals law ESPR should take into account.
"Registration, Evaluation, Authorisation and Restriction of Chemicals"
DPP design-guidance source for consulting product-group delegated acts, DPP information categories, public and restricted access, interoperability, and conformity-document handling.
"consult the delegated act for the specific product group"
Commission source describing the DPP as an ESPR mechanism to store and share product sustainability, durability, environmental, instruction, and conformity information.
ETSI technical source for DPP concepts and cross-references to ECHA candidate-list, authorisation-list, and SCIP information sources without turning them into ESPR duties.
Commission overview explaining that ESPR extends ecodesign beyond energy-related products and aims to improve circularity, energy performance, recyclability, and durability.
"improving their circularity, energy performance, recyclability and durability"
Official ESPR text for product-group delegated acts, performance and information requirements, digital product passports, conformity assessment, technical documentation, declarations of conformity, corrective action, market surveillance, and penalties.
"performance requirements or information requirements, or both"