RoHS vs REACH for electrical and electronic equipment

RoHS covers electrical and electronic equipment and restricts listed substances by maximum concentration value in each homogeneous material, unless an exclusion or exemption applies.

REACH is a general chemicals regime for registration, evaluation, authorisation, and restriction of chemical substances; the RoHS FAQ says it has a different scope and objective from RoHS.

Begin with two separate questions: is the item EEE under RoHS, and is there a separate REACH substance, mixture, article, restriction, or authorisation issue?

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.

The RoHS sources only support a narrow REACH actor comparison: REACH may involve chemical-regime actors outside the RoHS product-chain role map, so do not assign REACH work only by RoHS title.

Assign a RoHS product owner and a separate chemicals owner when the same electronics issue also raises REACH questions.

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%.

For this page, the supported REACH trigger is limited to overlap with REACH restrictions or authorisation, especially Annex XIV/XVII coherence mentioned in RoHS materials.

Do not answer a RoHS threshold question with a general REACH declaration, and do not assume a REACH review resolves RoHS homogeneous-material limits.

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.

REACH obligations are not fully grounded in this RoHS source set; the supported comparison is that REACH can impose separate registration, authorisation, restriction, and communication workstreams.

Build two action lists when both apply: RoHS release evidence for the product and a separate chemicals action list for the REACH issue.

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.

The RoHS grounding supports only a limited REACH evidence check. Keep REACH restriction, authorisation, and substance-communication evidence separate and cite the REACH source used for that conclusion.

A supplier declaration can support both files only if it identifies the substance, material or article boundary, concentration basis, date, and legal purpose.

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.

The RoHS materials do not provide a complete REACH calendar; use a separate REACH source for registration, authorisation, restriction, or communication deadlines.

Track RoHS exemption expiry and product-release dates separately from REACH chemical deadlines, then use the earliest blocking date for launch planning.

RoHS authorities may request information and documentation from manufacturers, importers, and distributors; the directive also requires corrective measures, withdrawal, recall, and penalties for infringements.

The RoHS source set supports only a high-level REACH enforcement distinction: REACH is a chemicals regime, so authority questions may not follow the RoHS CE-marking and product-documentation route.

Prepare separate response packs: one for RoHS product conformity and one for any REACH substance, restriction, authorisation, or communication issue.

RoHS allows coherence with REACH but remains its own product-compliance regime. RoHS exemptions may not weaken REACH environmental and human-health protection.

REACH overlap is real where Annex XIV or XVII matters, and the 2015 phthalates amendment shows that RoHS can defer to a REACH Annex XVII restriction to avoid double regulation in a specific toy case.

Reuse evidence only after writing a bridge note that states which law each artifact supports and where the stronger or more specific restriction controls.

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.

Treat REACH as a parallel issue only when a substance, mixture, article, restriction, authorisation, or communication duty remains after the RoHS question is answered.

The clean answer for visitors is usually one of four outcomes: RoHS only, REACH only, both with split evidence, or neither based on a documented product and substance boundary.