RoHS vs REACHEU

EU chemicals and product compliance RoHS vs REACH

Different scopes, one supply chain.

Use this page to separate obligations while sharing evidence and controls.

Back to main artifactReview sources
Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

RoHS and REACH are often confused because they both deal with hazardous substances. The fastest implementation approach is: keep the legal scopes separate, but build one shared supplier evidence backbone that can generate RoHS technical documentation and support REACH-related disclosures where relevant.

Section 1

Scope in one sentence

RoHS is a product rule for electrical and electronic equipment (EEE): it restricts specific substances above thresholds in homogeneous materials and is tied to CE evidence and technical documentation.

REACH is broader chemicals legislation covering substances, mixtures and articles through registration, authorisation, restriction, and SVHC communication obligations.

  • RoHS: EEE focus + Annex II substance thresholds + exemptions
  • REACH: chemicals lifecycle rules + restrictions and information duties
  • If you sell EEE, you may need both - but the evidence outputs differ
Section 2

Unit of control: homogeneous material vs article/chemical concepts

RoHS compliance is assessed at the homogeneous material level (the part of the product that cannot be mechanically disjointed).

REACH uses different concepts (substances/mixtures/articles) and different compliance mechanisms (e.g., restrictions and SVHC communication thresholds).

  • RoHS: thresholds applied to homogeneous materials in EEE
  • REACH: obligations depend on substance identity and use; article obligations can depend on SVHC concentration and tonnage/notification conditions
  • Practical takeaway: model your BOM to support both perspectives (material composition + article structure)
Recommended next step

Use EU chemicals and product compliance RoHS vs REACH as a cited research workflow

Research Copilot can take EU chemicals and product compliance RoHS vs REACH from how this topic compares with adjacent regulations or standards to a reusable workflow inside Sorena. Teams working on EU chemicals and product compliance can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Research workflow
Open Research Copilot for EU chemicals and product compliance RoHS vs REACH

Start from EU chemicals and product compliance RoHS vs REACH and answer scope, timing, and interpretation questions with cited outputs.

Explore next step
Talk to Sorena
Talk through EU chemicals and product compliance

Review your current process, evidence gaps, and next steps for EU chemicals and product compliance RoHS vs REACH.

Explore next step
Section 3

Overlap: substances and supply chain evidence

Substances can be regulated under both regimes (e.g., certain phthalates are SVHCs and also restricted in RoHS for EEE).

The overlap is operational: supplier declarations, composition data, and change control.

The overlap is also legal: Article 5 exemption decisions and Article 6 substance reviews under RoHS are supposed to stay coherent with REACH and should not weaken the environmental and health protection afforded by REACH.

  • Phthalates: added to RoHS Annex II by (EU) 2015/863; also regulated under REACH for some uses
  • Evidence backbone: supplier composition and restricted substances disclosures
  • Change control: prevent silent formulation changes in plastics, coatings, solders, and cable insulation
  • Exemptions are different: a RoHS Annex III or IV exemption does not remove separate REACH duties
Section 4

Different outputs (don't mix them up)

RoHS deliverables are CE-facing and product-specific: technical documentation (often EN IEC 63000-aligned), exemption register, and evidence per product family and variant.

REACH deliverables are chemicals-facing: restrictions compliance and information/communication obligations where relevant.

  • RoHS outputs: restricted substances evidence + exemptions tracking + EN IEC 63000 technical documentation
  • REACH outputs: restriction compliance evaluation + SVHC communication logic (where applicable)
  • One shared system: store composition and supplier evidence once; generate outputs for each regime
Primary sources

References and citations

Related guides

Explore more topics

EU RoHS FAQ (Scope, Exemptions, Phthalates, Technical File, CE) | RoHS Directive 2011/65/EU
High-signal EU RoHS FAQ grounded in official sources: what counts as EEE, staged applicability (22 July 2014/2017/2019).
EU RoHS Timeline: RoHS 1 (2002) -> RoHS 2 (2011/2013) -> Open Scope (2019) -> Phthalates (2019/2021)
A date-by-date EU RoHS timeline for implementers: RoHS 1 (2002), RoHS 2 recast and transposition (2011 - 2013).
Restricted Substances and Thresholds | EU RoHS Directive 2011/65/EU | Homogeneous Material Limits (0.1% / 0.01%) + Phthalates (2015/863)
A practical RoHS restricted substances guide for Directive 2011/65/EU: the 10 substances in Annex II, homogeneous material threshold logic (0.1% for most.
RoHS Applicability Test | Is My Product In Scope of EU RoHS Directive 2011/65/EU? | EEE, Cables, Spare Parts, Open Scope
A structured EU RoHS applicability test for Directive 2011/65/EU: determine if your product is electrical and electronic equipment (EEE).
RoHS Compliance Checklist | EU RoHS Directive 2011/65/EU | Supplier Evidence, Exemptions, EN IEC 63000 Technical File
An audit-ready RoHS compliance checklist for Directive 2011/65/EU: scope and EEE category mapping.
RoHS Compliance Program | EU RoHS Directive 2011/65/EU Implementation Playbook | Supplier Controls, Exemptions, Evidence
A practical RoHS compliance program playbook for Directive 2011/65/EU: set up governance, map homogeneous material risks across your BOM.
RoHS Deadlines and Compliance Calendar (2013, 2014, 2017, 2019, 2021) | EU RoHS Directive 2011/65/EU
A RoHS compliance calendar you can actually operationalize: staged applicability dates (22 July 2014/2017/2019).
RoHS Enforcement, Penalties, and Fines | EU RoHS Directive 2011/65/EU (Member State rules)
What EU RoHS enforcement looks like in practice: market surveillance checks, documentation requests, CE marking scrutiny.
RoHS Exemptions Tracker Guide | How to Build an Exemption Register (Annex III/IV), Link to BOM, Monitor Expiry
A practical guide to building a RoHS exemptions tracker: recommended tracker fields (exemption reference, exact wording, scope conditions.
RoHS Exemptions Tracking | Directive 2011/65/EU Annex III and Annex IV | Expiry Risk, Evidence, Renewal Strategy
A practical RoHS exemptions tracking guide for Directive 2011/65/EU: how Annex III and Annex IV exemptions work.
RoHS Requirements | EU RoHS Directive 2011/65/EU | Substance Restrictions (Annex II), Exemptions (Annex III/IV), CE Evidence
A practical RoHS requirements breakdown for Directive 2011/65/EU: restricted substances thresholds in homogeneous materials (Annex II).
RoHS Supplier Declaration Template | Annex II Substances, Homogeneous Material Coverage, Exemptions Disclosure
A practical RoHS supplier declaration template for Directive 2011/65/EU.
Supplier Declarations and Verification | RoHS Compliance Program | Supplier Questionnaires, Change Control, Risk-Based Testing
A practical supplier evidence playbook for EU RoHS Directive 2011/65/EU.
Technical Documentation and CE | RoHS Directive 2011/65/EU | EN IEC 63000, EU Declaration of Conformity, Evidence Vault
A practical RoHS technical documentation guide for Directive 2011/65/EU.