RoHS vs REACH for electrical and electronic equipment
RoHS is the sector-specific EU product rule for restricted substances in electrical and electronic equipment. REACH is the broader chemicals regime that can still apply to substances, mixtures, and articles in the same supply chain.
This comparison helps decide which workstream owns scope, substance limits, evidence, CE marking, exemption review, supplier communication, and overlap with REACH restrictions.
RoHS and REACH can both matter for electronics, but they do not answer the same question. RoHS asks whether electrical or electronic equipment placed on the EU market meets restricted-substance limits in each homogeneous material and the related product-compliance duties. REACH asks broader chemical questions, including registration, evaluation, authorisation, restriction, and communication duties for a in an article. Run both assessments where their triggers overlap; neither conclusion replaces the other.
Side-by-side comparison
RoHS vs REACH for electronics: side-by-side comparison
This comparison is relevant when an electrical or electronic product may need both RoHS product-compliance evidence and a separate REACH chemical-overlap check.
Sector-specific EU product-compliance workstream for electrical and electronic equipment, homogeneous-material substance limits, technical documentation, EU declaration of conformity, CE marking, and RoHS exemptions.
Second framework
REACH
Broader EU chemicals regime covering registration, evaluation, authorisation, restriction, and chemical communication. For electronics, check REACH separately from RoHS and document any Annex XIV or XVII overlap.
RoHS vs REACH for electronics: side-by-side comparison
RoHS covers electrical and electronic equipment and restricts listed substances by maximum concentration value in each homogeneous material, unless an exclusion or exemption applies.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
REACH applies to substances on their own, in mixtures, and in articles. Its controls include registration and evaluation, Candidate List and article communication, Annex XIV authorisation, and Annex XVII restrictions. EEE, components, and materials can be articles for REACH while RoHS also applies.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Define the object and substance boundary first: substance, mixture, article, component article, homogeneous material, or finished EEE. Then apply the RoHS and REACH tests independently.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
RoHS names product-chain economic operators: manufacturer, authorised representative, importer, and distributor. Manufacturers own conformity assessment, technical documentation, EU declaration, CE marking, and series-production control.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
REACH duties can attach to manufacturers and importers of substances, downstream users, distributors, producers and importers of articles, and suppliers of articles. The actor changes with the transaction and whether the item is a substance, mixture, or article.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Map the RoHS product role and REACH supply-chain role separately. Record who manufactures or imports the substance, who produces or imports the article, who supplies it, and the relevant annual tonnage.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS turns on when covered EEE is placed on the market and Annex II substances exceed tolerated concentrations in homogeneous materials; cadmium is listed at 0.01%, while the other listed Annex II substances are shown at 0.1%.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Adds DEHP, BBP, DBP, and DIBP to RoHS Annex II and explains the REACH Annex XVII overlap for certain phthalates in toys.
shall continue to be the only restriction applicable
Registration generally starts at one tonne or more per year per manufacturer or importer. Article 7(1) can require registration for substances intended to be released from articles above one tonne per year. Article 7(2) notification can apply to a above 0.1% weight by weight and over one tonne per year, subject to Article 7 exceptions. Article 33 communication uses the 0.1% article threshold without that one-tonne condition. Annex XIV and XVII add use-specific authorisation or restriction triggers.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Do not transfer the RoHS homogeneous-material percentage to REACH. Record the article boundary, concentration, tonnage, intended release, exposure, registration status, Candidate List date, and any Annex XIV or XVII entry.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS requires the manufacturer to ensure compliant EEE, draw up technical documentation, use the conformity assessment procedure, issue an EU declaration of conformity, affix CE marking, keep records, and respond to competent authorities.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Official source citing EN IEC 63000:2018 for RoHS technical documentation for assessing materials, components, and EEE.
technical documentation required for assessing materials
REACH can require substance registration, compliance with Annex XVII conditions, authorisation before specified Annex XIV uses after a sunset date, Article 33 information to recipients, a consumer response within 45 days, and Article 7 notification or registration for articles when its conditions are met.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Create a REACH action for each live trigger, with an owner, deadline, substance identity, use, article boundary, tonnage, supply-chain communication, submission or authorisation reference, restriction condition, and closure evidence.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS evidence should connect the BOM and material declarations to homogeneous materials, Annex II substances, exemptions, tests or assessments, EN IEC 63000 technical documentation, EU declaration of conformity, and CE marking.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
IEC source describing the technical documentation a manufacturer compiles to declare compliance with applicable substance restrictions.
declare compliance with the applicable substance restrictions
REACH evidence can include substance identity and composition, tonnage calculations, registration numbers and use coverage, safety data and exposure information, Candidate List screening, article concentration and boundary records, Article 33 communications, consumer-response controls, Article 7 submissions or exception rationales, Annex XIV authorisations, and Annex XVII condition checks.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
A supplier declaration can support both files only if it identifies the substance, material or article boundary, concentration basis, covered parts and revisions, date, legal purpose, and any use or tonnage conditions. Record what remains unproved.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS timing includes market placement, application dates for substance restrictions, 10-year retention of technical documentation and EU declarations, series-production controls, and time-limited Annex III or IV exemptions.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission source for exemption requests, renewal timing, and the practical exemption process under RoHS.
Exemptions are limited in time
REACH timing is event-specific. Candidate List inclusion can activate Article 33 communication; the Article 7 notification provisions apply six months after identification under Article 59(1). Consumers must receive Article 33 information within 45 days of a request. Annex XIV entries specify latest application and sunset dates, Annex XVII entries specify their own conditions and dates, and registration or tonnage changes must be controlled as manufacture and import volumes change.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Track RoHS placement and exemption dates separately from Candidate List updates, consumer-response deadlines, tonnage thresholds, registration changes, and Annex XIV or XVII dates. Use the earliest unsatisfied condition for supply or use.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
RoHS authorities may request information and documentation from manufacturers, importers, and distributors; the directive also requires corrective measures, withdrawal, recall, and penalties for infringements.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Market-surveillance source for EU product compliance controls and cooperation with authorities where RoHS products are checked.
market surveillance and compliance of products
REACH enforcement is carried out by Member States under national measures and penalties. Authorities may examine registration, restriction, authorisation, safety-data, article notification, or communication evidence; the response is not based on RoHS CE marking or its EU declaration.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Prepare separate response packs. The REACH pack should identify the substance, actor, supply chain, article or mixture boundary, concentration, tonnage, use, registration or authorisation reference, restriction condition, communications, dates, and corrective action.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
RoHS allows coherence with REACH but remains its own product-compliance regime. RoHS exemptions may not weaken REACH environmental and human-health protection.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
REACH overlap includes restrictions on substances also relevant to EEE and article communication for Candidate List substances not restricted by RoHS. The 2015 phthalates amendment leaves DEHP, BBP, and DBP in toys to the referenced REACH Annex XVII restriction rather than duplicating it under RoHS.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Write a bridge note for each shared substance. State the RoHS material limit or exemption, the REACH article, authorisation, or restriction rule, the measurement boundary, the stricter or more specific condition, and the evidence supporting each conclusion.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
Treat RoHS as controlling when the immediate decision is EEE scope, homogeneous-material concentration, RoHS exemption, technical documentation, EU declaration, CE marking, or market placement.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Official source citing EN IEC 63000:2018 for RoHS technical documentation for assessing materials, components, and EEE.
technical documentation required for assessing materials
Use REACH when the open issue is substance registration or tonnage, intended release, a in an article, recipient or consumer communication, Annex XIV authorisation, Annex XVII restriction, or a chemicals supply-chain duty.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Record RoHS and REACH as two decisions. Each should state in scope or out of scope, actor, trigger, provision, evidence, exception, date, owner, and reassessment event.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
Scope and covered activity
RoHS
RoHS covers electrical and electronic equipment and restricts listed substances by maximum concentration value in each homogeneous material, unless an exclusion or exemption applies.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
REACH
REACH applies to substances on their own, in mixtures, and in articles. Its controls include registration and evaluation, Candidate List and article communication, Annex XIV authorisation, and Annex XVII restrictions. EEE, components, and materials can be articles for REACH while RoHS also applies.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Define the object and substance boundary first: substance, mixture, article, component article, homogeneous material, or finished EEE. Then apply the RoHS and REACH tests independently.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Who must act
RoHS
RoHS names product-chain economic operators: manufacturer, authorised representative, importer, and distributor. Manufacturers own conformity assessment, technical documentation, EU declaration, CE marking, and series-production control.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
REACH
REACH duties can attach to manufacturers and importers of substances, downstream users, distributors, producers and importers of articles, and suppliers of articles. The actor changes with the transaction and whether the item is a substance, mixture, or article.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Map the RoHS product role and REACH supply-chain role separately. Record who manufactures or imports the substance, who produces or imports the article, who supplies it, and the relevant annual tonnage.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
Trigger or threshold
RoHS
RoHS turns on when covered EEE is placed on the market and Annex II substances exceed tolerated concentrations in homogeneous materials; cadmium is listed at 0.01%, while the other listed Annex II substances are shown at 0.1%.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Adds DEHP, BBP, DBP, and DIBP to RoHS Annex II and explains the REACH Annex XVII overlap for certain phthalates in toys.
shall continue to be the only restriction applicable
REACH
Registration generally starts at one tonne or more per year per manufacturer or importer. Article 7(1) can require registration for substances intended to be released from articles above one tonne per year. Article 7(2) notification can apply to a above 0.1% weight by weight and over one tonne per year, subject to Article 7 exceptions. Article 33 communication uses the 0.1% article threshold without that one-tonne condition. Annex XIV and XVII add use-specific authorisation or restriction triggers.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Do not transfer the RoHS homogeneous-material percentage to REACH. Record the article boundary, concentration, tonnage, intended release, exposure, registration status, Candidate List date, and any Annex XIV or XVII entry.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
Core obligations
RoHS
RoHS requires the manufacturer to ensure compliant EEE, draw up technical documentation, use the conformity assessment procedure, issue an EU declaration of conformity, affix CE marking, keep records, and respond to competent authorities.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Official source citing EN IEC 63000:2018 for RoHS technical documentation for assessing materials, components, and EEE.
technical documentation required for assessing materials
REACH
REACH can require substance registration, compliance with Annex XVII conditions, authorisation before specified Annex XIV uses after a sunset date, Article 33 information to recipients, a consumer response within 45 days, and Article 7 notification or registration for articles when its conditions are met.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Create a REACH action for each live trigger, with an owner, deadline, substance identity, use, article boundary, tonnage, supply-chain communication, submission or authorisation reference, restriction condition, and closure evidence.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
Evidence and records
RoHS
RoHS evidence should connect the BOM and material declarations to homogeneous materials, Annex II substances, exemptions, tests or assessments, EN IEC 63000 technical documentation, EU declaration of conformity, and CE marking.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
IEC source describing the technical documentation a manufacturer compiles to declare compliance with applicable substance restrictions.
declare compliance with the applicable substance restrictions
REACH
REACH evidence can include substance identity and composition, tonnage calculations, registration numbers and use coverage, safety data and exposure information, Candidate List screening, article concentration and boundary records, Article 33 communications, consumer-response controls, Article 7 submissions or exception rationales, Annex XIV authorisations, and Annex XVII condition checks.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
A supplier declaration can support both files only if it identifies the substance, material or article boundary, concentration basis, covered parts and revisions, date, legal purpose, and any use or tonnage conditions. Record what remains unproved.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
Timing and cadence
RoHS
RoHS timing includes market placement, application dates for substance restrictions, 10-year retention of technical documentation and EU declarations, series-production controls, and time-limited Annex III or IV exemptions.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission source for exemption requests, renewal timing, and the practical exemption process under RoHS.
Exemptions are limited in time
REACH
REACH timing is event-specific. Candidate List inclusion can activate Article 33 communication; the Article 7 notification provisions apply six months after identification under Article 59(1). Consumers must receive Article 33 information within 45 days of a request. Annex XIV entries specify latest application and sunset dates, Annex XVII entries specify their own conditions and dates, and registration or tonnage changes must be controlled as manufacture and import volumes change.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Track RoHS placement and exemption dates separately from Candidate List updates, consumer-response deadlines, tonnage thresholds, registration changes, and Annex XIV or XVII dates. Use the earliest unsatisfied condition for supply or use.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission source for exemption requests, renewal timing, and the practical exemption process under RoHS.
Exemptions are limited in time
Enforcement or assurance route
RoHS
RoHS authorities may request information and documentation from manufacturers, importers, and distributors; the directive also requires corrective measures, withdrawal, recall, and penalties for infringements.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Market-surveillance source for EU product compliance controls and cooperation with authorities where RoHS products are checked.
market surveillance and compliance of products
REACH
REACH enforcement is carried out by Member States under national measures and penalties. Authorities may examine registration, restriction, authorisation, safety-data, article notification, or communication evidence; the response is not based on RoHS CE marking or its EU declaration.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Prepare separate response packs. The REACH pack should identify the substance, actor, supply chain, article or mixture boundary, concentration, tonnage, use, registration or authorisation reference, restriction condition, communications, dates, and corrective action.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Market-surveillance source for EU product compliance controls and cooperation with authorities where RoHS products are checked.
market surveillance and compliance of products
Overlap and reuse
RoHS
RoHS allows coherence with REACH but remains its own product-compliance regime. RoHS exemptions may not weaken REACH environmental and human-health protection.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
REACH
REACH overlap includes restrictions on substances also relevant to EEE and article communication for Candidate List substances not restricted by RoHS. The 2015 phthalates amendment leaves DEHP, BBP, and DBP in toys to the referenced REACH Annex XVII restriction rather than duplicating it under RoHS.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Write a bridge note for each shared substance. State the RoHS material limit or exemption, the REACH article, authorisation, or restriction rule, the measurement boundary, the stricter or more specific condition, and the evidence supporting each conclusion.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
Adds DEHP, BBP, DBP, and DIBP to RoHS Annex II and explains the REACH Annex XVII overlap for certain phthalates in toys.
shall continue to be the only restriction applicable
Practical decision rule
RoHS
Treat RoHS as controlling when the immediate decision is EEE scope, homogeneous-material concentration, RoHS exemption, technical documentation, EU declaration, CE marking, or market placement.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Official source citing EN IEC 63000:2018 for RoHS technical documentation for assessing materials, components, and EEE.
technical documentation required for assessing materials
REACH
Use REACH when the open issue is substance registration or tonnage, intended release, a in an article, recipient or consumer communication, Annex XIV authorisation, Annex XVII restriction, or a chemicals supply-chain duty.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
Registration, Evaluation, Authorisation and Restriction of Chemicals
Operational implication
Record RoHS and REACH as two decisions. Each should state in scope or out of scope, actor, trigger, provision, evidence, exception, date, owner, and reassessment event.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
RoHS and REACH are two different acts
Practical decision rule
How should teams decide between RoHS and REACH for compliance planning?
If the question is about EEE scope, homogeneous-material limits, CE marking, technical documentation, or a RoHS exemption, start with RoHS.
If the question is about registration, authorisation, restriction, or chemical communication for a substance, start with REACH.
If both a product rule and a chemicals rule may apply, document each one separately and use the stronger restriction where the same substance is covered by both regimes.
General EU product-law guidance for economic operator roles, CE marking, EU declarations, and market surveillance concepts.
The manufacturer is responsible for the conformity assessment of the product and is subject to a series of obligations including traceability requirements.
Binding EU market surveillance source used for enforcement, economic operator, and border-control comparisons.
market surveillance and compliance of products
1
Section 1
What RoHS answers that REACH does not
RoHS applies to electrical and electronic equipment within Directive 2011/65/EU unless an exclusion or exemption applies. The directive sets maximum concentration values by weight in homogeneous materials for Annex II substances, including lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and the four phthalates added by Delegated Directive (EU) 2015/863.
That makes RoHS a product-release control. The manufacturer must draw up technical documentation, complete the conformity assessment route, issue an EU declaration of conformity, and affix CE marking before the finished EEE is placed on the market. Importers and distributors have their own checks, hold-back duties, cooperation duties, and authority-response duties.
Check whether the item is EEE, a cable, a component, a spare part, or a separately placed product because the RoHS FAQ treats these cases differently for substance restrictions, CE marking, and declarations.
Test and declaration work should be tied to homogeneous materials, not only finished-product averages or supplier-level statements.
Keep exemptions specific to the application, Annex entry, product category, expiry or renewal status, and the evidence showing why the restricted substance is still used.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
Adds DEHP, BBP, DBP, and DIBP to RoHS Annex II and explains the REACH Annex XVII overlap for certain phthalates in toys.
shall continue to be the only restriction applicable
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Section 2
Where REACH still belongs in a RoHS file
The Commission FAQ states that RoHS and REACH are different acts with different scopes and objectives. It also states that RoHS does not affect REACH, and vice versa, for restriction of substances in EEE. When the same substance is covered by both regimes, the RoHS guidance says the stronger restriction, meaning the lower maximum concentration, should be applied.
RoHS itself also requires future review and amendment of Annex II to be coherent with chemicals legislation, especially REACH Annexes XIV and XVII. The 2015 phthalates amendment gives a practical example: DEHP, BBP, and DBP in toys remain controlled by the REACH Annex XVII toy restriction rather than a duplicate RoHS restriction.
REACH also creates article duties that have no RoHS equivalent. If an article contains a above 0.1% weight by weight, Article 33 requires the supplier to provide recipients with enough information for safe use and at least the substance name; a consumer must receive that information on request within 45 days. Article 7(2) notification to ECHA can apply when the same concentration threshold is exceeded and the substance totals more than one tonne per producer or importer per year, unless an Article 7 exception applies. Article 7(7) gives a six-month period after Candidate List identification for the notification provisions; record the inclusion date separately from the immediate Article 33 communication assessment.
Use REACH in this page as an overlap check, not as a complete REACH compliance manual.
Record whether the issue is a RoHS product restriction, a REACH restriction or authorisation issue, an Article 33 article-communication duty, an Article 7 notification duty, or more than one of these.
Do not treat a RoHS exemption as permission under REACH; RoHS exemption decisions must not weaken the environmental and health protection afforded by REACH.
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
maximum concentration value by weight in homogeneous materials
Consolidated source for Article 7 notification conditions and exceptions, Article 33 Candidate List substance communication for articles, Annex XIV authorisation, Annex XVII restrictions, and the broader REACH framework.
Registration, Evaluation, Authorisation and Restriction of Chemicals
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Section 3
Evidence that works for the comparison
A useful RoHS-vs-REACH record separates cited facts from supplier assurances. For RoHS, the record should show the product scope decision, homogeneous-material assessment, Annex II substance matrix, exemptions relied on, supplier material declarations, test or screening rationale, technical documentation, EU declaration of conformity, CE-marking checks, and change-control trigger.
EN IEC 63000 is the harmonised technical-documentation reference cited for RoHS assessment of materials, components, and EEE. It does not supersede the need to understand the product boundary, supplier risk, exemption expiry, or a separate REACH restriction question.
Tag each document by purpose: RoHS scope, RoHS substance evidence, RoHS exemption, RoHS CE/DoC, REACH overlap, or supplier follow-up.
Reopen the file when the BOM, supplier, polymer or coating, cable configuration, spare-part use, exemption status, harmonised standard, or Annex II substance list changes.
If a customer asks for both RoHS and REACH evidence, provide a split response that says what each document proves and what it does not prove.
Commission source for exemption requests, renewal timing, and the practical exemption process under RoHS.
Exemptions are limited in time
Recommended next step
Build a RoHS and REACH evidence split that reviewers can trust
Turn the comparison into a cited release checklist: RoHS scope, homogeneous-material evidence, exemptions, technical documentation, CE marking, and a narrow REACH overlap note where the RoHS sources support it.
Consolidated REACH text for registration, Article 7 article notification and exceptions, Article 33 communication and 45-day consumer responses, Annex XIV authorisation, and Annex XVII restrictions. Consolidations are documentation tools; the Official Journal acts are the authentic legal texts.
Consolidated source for Article 7 notification conditions and exceptions, Article 33 Candidate List substance communication for articles, Annex XIV authorisation, Annex XVII restrictions, and the broader REACH framework.
REACH source cited only for the narrow comparison points supported by RoHS materials: registration, evaluation, authorisation, restriction, and RoHS coherence with Annexes XIV and XVII.
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Consolidated REACH source used for chemical-scope comparisons.
"Registration, Evaluation, Authorisation and Restriction of Chemicals"
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances. Consolidations are documentation tools; the Official Journal acts are the authentic legal texts.
Consolidated RoHS source for EEE scope, homogeneous-material limits, economic-operator duties, technical documentation, EU declarations of conformity, CE marking, exemptions, and review of restricted substances.
Consolidated RoHS source for scope, substance thresholds, exemptions, technical documentation, CE marking, and categories.
"maximum concentration value by weight in homogeneous materials"
More quoted passages
"restriction of the use of certain hazardous substances"
General EU product-law guidance for economic operator roles, CE marking, EU declarations, and market surveillance concepts.
"The manufacturer is responsible for the conformity assessment of the product and is subject to a series of obligations including traceability requirements."
Commission FAQ used for the RoHS and REACH relationship, cables, components, spare parts, CE marking, declarations of conformity, and technical-documentation context.