RoHS and REACH are often used interchangeably in the same sentence: “has this product passed REACH and RoHS?”. But these two sets of regulations have essentially different scope, limits and obligations. Using a report from one ministry to respond to another ministry is one of the most common errors in export documents to the EU.
This article compares the two sets of regulations according to five practical criteria: scope, substance list, limit calculation, information obligation and overlaps commonly encountered by e-businesses.
1. The two sets of regulations are different in nature
| Criteria | RoHS | REACH |
|---|---|---|
| Nature | Limit a list of substances in electrical and electronic equipment | General chemical management framework for all products circulating on the EU market |
| Scope | Electrical and electronic equipment falls within the scope of the Directive | Chemicals, mixtures and products (article) — almost every type of commodity |
| List of substances | List of fixed restricted substances (10 substances) | Various categories: candidate substance list, restrictions addendum, licensing addendum |
| How to calculate limit | According to homogeneous material | Depending on the mechanism: limit based on product, material or specific usage conditions |
| Typical obligations | Conformity assessment, CE marking, declaration of conformity, technical documents | Inform customers when a candidate substance is present in the product; declare into the database of the European agency; comply with applicable restrictions and licensing |
2. The most important difference: how to calculate the 0.1% limit
Both sets mention 0.1%, but the meaning is completely different — and this is the source of a lot of misunderstanding:
- In RoHS: limit of 0.1% by volume homogeneous material (Cadmium alone has a stricter limit). This means that each individual material must be evaluated independently.
- In REACH: The 0.1% level attaches to the information obligation when a product contains a candidate substance in excess of that level, and the calculation is often associated with the whole product rather than individual homogeneous materials.
Therefore, a product can meet RoHS at the material level and still have information obligations under REACH at the product level — and vice versa.
3. Information obligations under REACH that e-businesses often miss
Three obligations are often overlooked when businesses focus solely on RoHS:
- Provide information to customers when the product contains a substance on the list of candidate substances that exceeds the prescribed level. This obligation applies to both finished goods and components sold separately.
- Updated when substance list changes. The list of candidate substances is supplemented over time, so a “REACH passed” profile may no longer be correct after several updates.
- Declare into the database of the European agency For products containing excess candidate substances, according to the roadmap applied from the beginning of 2021.
For the electronics supply chain, substances that often appear in the candidate list are plasticizers, some flame retardants, and heavy metals in alloys or coatings.
4. Four common misunderstandings
| Misunderstanding | Reality | How to avoid |
|---|---|---|
| “REACH only applies to chemicals, not electronic components” | REACH applies to all products circulating in the EU market, including components | Added question about candidate substances in material declaration form |
| “Having RoHS report is enough for REACH” | The two sets have different substance lists; RoHS reports typically include only 10 restricted substances | Require declaration under both categories from the beginning |
| “The 0.1% limit is the same in both sets” | RoHS calculated according to homogeneous materials; REACH calculates according to the separate mechanism of each obligation | Clearly state the basis of calculation in all reports and declarations |
| “REACH will replace RoHS” | Two sets in parallel; RoHS is a specialized regulation for electrical and electronic equipment | Manage two sets of obligations in the same product profile |
5. Manage two sets of obligations in one profile
| Things to do | Serving RoHS | Serving REACH |
|---|---|---|
| Uniform material list by product code | Yes | Yes (is the basis for recalculation by product) |
| Supplier’s material declaration | Yes | Yes |
| Check the restricted substances list | Yes | No replacement |
| Check the list of candidate substances | No replacement | Yes |
| Periodic test reports for risky materials | Yes | Useful when it is necessary to demonstrate the concentration of a candidate substance |
| Information provided to customers | Declaration of conformity | Information on candidate substances with instructions for safe use |
The upside: much of the data collection work is common to both. If the declaration form is designed correctly from the beginning, businesses do not have to ask the supplier again every time the customer switches from RoHS requirements to REACH requirements.
6. Frequently asked questions
If the product already has a RoHS report, does anything need to be done for REACH?
It is necessary to check whether the product contains any substances on the list of candidate substances that exceed the prescribed levels, and whether there is a corresponding information obligation. The RoHS report only includes the restricted substance list, which is not enough to answer.
Are loose components covered by REACH?
Yes. REACH applies to products circulating on the EU market, including components sold separately. Therefore, declaration requests from European customers increasingly include candidate substance lists.
Do I need to declare it in the European agency’s database?
This obligation is associated with the product containing the candidate substance in excess of the prescribed level, and is usually the responsibility of the party bringing the product to market. Manufacturing enterprises need to provide data for that party to perform.
If there is no candidate substance in the product, what should be done?
It is still recommended to have written confirmation and save supporting data, because the list of candidate substances is periodically updated and customers can ask again after each update.
Do Vietnamese businesses have direct obligations under REACH?
The obligation largely lies with the party bringing the product to the EU market, but in fact exporting businesses still have to provide data to meet contracts and customer requirements. This is a contractual obligation, but it is also a real commercial risk.
7. Conclusion
RoHS and REACH are two parallel frameworks, not replacing each other. RoHS restricts 10 substances in electrical and electronic equipment with limits based on homogeneous materials; REACH regulates chemicals in general with a variety of limit mechanisms and information obligations.
Three things to do: design a common material declaration form for both sets; clearly state the basis for calculating the limit in all documents; and periodically monitor updates to the list of candidate substances so as not to be passive when customers ask again.
References
- Directive 2011/65/EU and its amendments (RoHS).
- Regulation (EC) 1907/2006 on the registration, evaluation, authorization and restriction of chemicals (REACH).
- Obligation for information on substances contained in products and the database of products containing candidate substances of the European Chemicals Agency.
- IEC 62474 — Material declaration for products of and for the electrotechnical industry.
Related articles
- 7 errors caused electronic shipments to be detained at EU border gates because of RoHS
- Material declaration according to IEC 62474 and IPC-1752A: what must the supply chain send and receive?
- RoHS and WEEE: one side restricts the substance, the other side is responsible for recall
- RoHS and ELV: two different sets of substance limits for electronics and automobiles
- 10 RoHS restricted substances: how do the 0.1% and 0.01% limits apply to “homogeneous materials”?
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Disclaimer
This article is an interpretive content compiled by us; not legal advice. Enterprises need to compare relevant documents/standards verbatim before applying them to specific products.
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