Difference Between RoHS & REACH
RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) are two distinct but complementary EU regulations governing chemicals in products.
Key Distinction
RoHS restricts specific hazardous substances in electrical/electronic equipment. REACH addresses chemical substances more broadly, with provisions for registration, evaluation, authorization, and restriction of chemicals.
Comparison of RoHS vs REACH
| Feature | RoHS Directive | REACH Regulation |
|---|---|---|
| Full Name | Restriction of Hazardous Substances | Registration, Evaluation, Authorisation and Restriction of Chemicals |
| Scope | Electrical & Electronic Equipment (EEE) | All chemical substances (including in products/articles) |
| Primary Focus | Restricting specific hazardous substances | Registration, evaluation, authorization of chemicals |
| Number of Restricted Substances | 10 substances (currently) | Over 200 substances on Candidate List (growing) |
| Concentration Limits | 0.1% or 0.01% by weight (homogeneous material) | Varies by substance (often 0.1% w/w for articles) |
| Declaration Required | RoHS Declaration of Conformity | REACH Declaration or SDS (Safety Data Sheet) |
| Enforcement | Market surveillance authorities | ECHA (European Chemicals Agency) + national authorities |
How They Work Together
RoHS: Targeted Restrictions
RoHS prohibits 10 specific substances in electrical/electronic products. It's product-focused: "This product must not contain these substances above these limits."
Example: Lead in solders, mercury in switches, cadmium in plastics.
REACH: Comprehensive Management
REACH manages chemicals throughout their lifecycle. It includes registration of substances, communication in supply chains, and restrictions on hazardous substances.
Example: SVHC (Substances of Very High Concern) in any product component.
Restricted Substances
RoHS Restricted Substances (10 substances)
RoHS restricts these 10 substances in electrical and electronic equipment (with specific exemptions):
Common in solder, paints, PVC stabilizers. Many exemptions exist for specific applications.
Used in pigments, coatings, batteries. Stricter limit due to high toxicity.
Found in switches, fluorescent lamps, measuring devices.
Used in metal coatings for corrosion resistance.
RoHS Exemptions Are Critical
Many applications have specific exemptions (e.g., lead in high-temperature solders, cadmium in photovoltaic panels). These exemptions have expiration dates and must be checked regularly. Using an expired exemption is a compliance violation.
REACH SVHC (Substances of Very High Concern)
REACH maintains a Candidate List of SVHCs that currently includes over 200 substances. Key substance groups include:
Check Common Restricted Substances
Plasticizers used in PVC and other plastics. Restricted under both RoHS and REACH for certain applications. Often found in cables, toys, flooring.
Restricted RoHS & REACHUsed in polycarbonate plastics and epoxy resins. On REACH Candidate List as endocrine disruptor. Common in food containers, electronics casings.
SVHC Candidate REACH"Forever chemicals" used for water/stain resistance. Increasingly restricted globally. Found in textiles, coatings, cookware.
Restricted REACH (expanding)Key REACH Requirements for Importers
- SVHC Notification: If article contains >0.1% w/w of an SVHC, you must notify ECHA and provide information to customers
- Communication: Supply safety data sheets (SDS) for hazardous substances/mixtures
- Restrictions: Comply with restrictions listed in Annex XVII of REACH
- Registration: If importing >1 ton/year of a substance, may need to register with ECHA
Factory Testing & Declarations
Testing Methods for Compliance Verification
Factories use various methods to verify material compliance. Understanding these helps you assess their reliability.
1. XRF Screening (X-ray Fluorescence)
Purpose: Quick, non-destructive screening for restricted metals (Pb, Cd, Hg, Cr, Br for RoHS).
Limitations: Cannot detect chemical forms (e.g., cannot distinguish Cr6+ from Cr3+). Not suitable for organic compounds like phthalates.
When Used: Incoming material inspection, production line screening.
2. Wet Chemistry / ICP Testing
Purpose: Accurate quantitative analysis. Can detect specific chemical forms and organic compounds.
Process: Material digestion followed by analysis (ICP-OES, ICP-MS, GC-MS).
When Used: For definitive compliance verification, supplier qualification, responding to failures.
3. Supplier Declarations & Material Certificates
Purpose: Documentary evidence from material suppliers.
Requirements: Must be specific (material, batch, test standard), signed, and traceable.
When Used: As supporting evidence, but should be backed by periodic testing.
Required Compliance Documents
RoHS Declaration of Conformity Requirements
A valid RoHS DoC must include: (1) Manufacturer/importer details, (2) Product identification, (3) Reference to RoHS Directive 2011/65/EU, (4) Declaration statement, (5) Place and date, (6) Authorized signature. It should be based on test reports or other evidence.
How Buyers Verify Compliance
Due Diligence Process for Importers
As the importer placing products on the EU market, you are legally responsible for compliance. Follow this verification process:
1. Supplier Qualification
Evaluate factory's compliance systems, testing capabilities, and track record. Ask for their compliance procedures and past audit results.
2. Document Review
Review RoHS DoC, test reports, material certificates. Check dates, scope, testing standards, and lab accreditation.
3. Independent Testing
Conduct random testing of finished products or materials through accredited third-party labs, especially for high-risk components.
4. Ongoing Monitoring
Implement systems for material change notifications, regular re-testing, and monitoring regulation updates.
Red Flags in Factory Compliance
- Generic test reports not tied to specific materials/batches
- Outdated test reports (older than material changes)
- Claims of "RoHS compliance" without supporting test reports
- Inability to provide material declarations from their suppliers
- No system for tracking material changes
- Test reports from non-accredited or questionable labs
- Declarations signed by unauthorized persons
The Cost of Non-Compliance
Penalties for RoHS/REACH violations include: (1) Product recalls at your expense, (2) Fines up to several million euros, (3) Criminal charges for serious violations, (4) Import bans on your products, (5) Reputational damage and loss of customer trust.
Contractual Protections for Buyers
Include these clauses in your supplier agreements:
- Compliance Warranty: Supplier warrants full RoHS/REACH compliance
- Indemnification: Supplier pays all costs from compliance failures
- Material Change Notification: Required advance notice of material changes
- Right to Audit: Your right to audit compliance systems and testing
- Documentation Retention: Supplier must maintain records for 10+ years
- Testing Rights: Your right to conduct independent testing at supplier's expense if issues arise
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