April 29, 2025

REACH vs RoHS: Key Differences Explained

REACH and RoHS are two separate European Union regulatory frameworks that control hazardous substances and chemical risks. REACH has broad application across chemical substances, mixtures, and articles, while RoHS applies specifically to electrical and electronic equipment (EEE) within its scope.

For many electrical and electronic products sold in the EU, both REACH and RoHS requirements may apply to the same product. A manufacturer may need to verify RoHS restricted substances in homogeneous materials while also evaluating REACH restrictions and Substances of Very High Concern (SVHCs).

REACH vs RoHS at a Glance

Requirement	REACH	RoHS
Full name	Registration, Evaluation, Authorisation and Restriction of Chemicals	Restriction of Hazardous Substances
Main legislation	Regulation (EC) No 1907/2006	Directive 2011/65/EU, as amended
Main purpose	Management of chemical risks	Restriction of hazardous substances in EEE
Product scope	Substances, mixtures, and articles across many industries	Electrical and electronic equipment within scope
Restricted substances	Depends on applicable REACH provisions, including Annex XVII	10 restricted substances
SVHC requirements	Yes	No separate SVHC Candidate List
Typical concentration limits	Depend on the specific REACH requirement	Generally 0.1% in homogeneous materials; 0.01% for cadmium
Registration requirements	May apply to substances manufactured or imported at applicable quantities	No substance registration system
CE marking	REACH itself does not require CE marking	RoHS compliance forms part of applicable CE conformity requirements for EEE
Compliance evidence	Regulatory assessment, supplier information, declarations and testing where appropriate	Technical documentation, supplier evidence and testing where appropriate

The most important practical distinction is scope. REACH can affect products across almost every consumer and industrial sector. RoHS is specifically associated with electrical and electronic equipment.

What is REACH?

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals.

It is established under Regulation (EC) No 1907/2006 and forms a central part of the EU regulatory framework for chemical substances.

REACH can apply to:

Chemical substances
Mixtures
Materials
Components
Finished products classified as articles

Its requirements can affect industries including textiles, footwear, toys, furniture, automotive components, packaging, electrical products, plastics, rubber products, and many other consumer goods.

The exact obligations depend on factors including the substance, quantity, use, product structure, concentration, and role of the business within the supply chain.

Key REACH Requirements

REACH contains several different regulatory mechanisms.

Registration

Companies manufacturing or importing chemical substances into the EU in quantities of one tonne or more per year generally need to determine whether registration is required.

Registration involves submitting information about the substance and its properties to the European Chemicals Agency (ECHA).

Evaluation

ECHA and EU Member States evaluate information submitted under REACH and may request additional information where necessary.

This is primarily part of the regulatory management of chemical substances.

Authorisation

Substances identified as SVHCs may eventually be included in Annex XIV, the Authorisation List.

Certain uses of substances included in Annex XIV may require authorisation after the applicable sunset date unless an exemption or other relevant provision applies.

Restriction

Annex XVII establishes restrictions on specific substances, mixtures, and articles.

Each restriction has its own scope and conditions. Limits may depend on the substance, material, product category, concentration, or intended use.

SVHC Requirements

REACH also establishes requirements concerning Substances of Very High Concern (SVHCs) included on the Candidate List.

When an article contains a Candidate List SVHC above 0.1% weight by weight (w/w), supply-chain communication requirements under Article 33 may apply.

Additional notification obligations may apply under certain circumstances.

For a detailed explanation of these requirements, see our REACH Compliance Guide.

What is RoHS?

RoHS stands for Restriction of Hazardous Substances.

The current EU framework is primarily established through Directive 2011/65/EU, commonly known as RoHS 2, together with subsequent amendments.

RoHS restricts the use of certain hazardous substances in electrical and electronic equipment placed on the EU market.

Products within its scope can include:

Household appliances
IT and telecommunications equipment
Consumer electronics
Lighting equipment
Electrical and electronic tools
Toys with electrical or electronic functions
Monitoring and control instruments
Medical devices
Other qualifying electrical and electronic equipment

Whether a specific product falls within scope should be assessed against the Directive, including applicable exclusions and exemptions.

Which Substances Are Restricted Under RoHS?

EU RoHS currently restricts 10 substances.

Restricted Substance	Maximum Concentration Value
Lead (Pb)	0.1%
Mercury (Hg)	0.1%
Cadmium (Cd)	0.01%
Hexavalent Chromium (Cr VI)	0.1%
Polybrominated Biphenyls (PBB)	0.1%
Polybrominated Diphenyl Ethers (PBDE)	0.1%
Bis(2-ethylhexyl) phthalate (DEHP)	0.1%
Benzyl butyl phthalate (BBP)	0.1%
Dibutyl phthalate (DBP)	0.1%
Diisobutyl phthalate (DIBP)	0.1%

These maximum concentration values generally apply by weight in homogeneous materials, subject to applicable exemptions.

A homogeneous material is a material of uniform composition that cannot be mechanically separated into different materials.

For example, a power cable may contain a conductor, insulation, coating, and other materials. RoHS assessment considers the relevant homogeneous materials individually.

What Is the Difference Between REACH and RoHS?

The differences become clearer when we look at their scope, regulated substances, compliance mechanisms, and product requirements.

1. REACH Covers a Much Broader Range of Products

REACH applies across many industries because it regulates chemical substances and their use in mixtures and articles.

A pair of shoes, textile garment, plastic kitchen accessory, piece of furniture, electronic device, or automotive component can all have REACH obligations depending on their materials and chemical composition.

RoHS has a defined product scope focused on electrical and electronic equipment.

A conventional pair of shoes, for example, would generally fall outside RoHS because it is not electrical or electronic equipment. REACH chemical restrictions may still apply to its leather, textile, rubber, plastic, coating, and metal components.

An electronic product may fall within both frameworks.

2. REACH and RoHS Regulate Substances Differently

RoHS establishes a defined list of restricted substances with maximum concentration values in homogeneous materials.

REACH has a broader and more complex structure.

Relevant chemical controls may come from:

Annex XVII restrictions
Candidate List SVHC requirements
Annex XIV authorisation requirements
Registration obligations
Other applicable provisions of the Regulation

For this reason, there is no single universal “REACH restricted substance limit.”

Each applicable requirement must be evaluated separately.

3. REACH Includes SVHC Requirements

One important feature of REACH is the Candidate List of Substances of Very High Concern.

When an article contains a Candidate List SVHC above the applicable 0.1% w/w threshold, communication requirements can apply.

RoHS does not use the REACH Candidate List system.

This distinction matters because a product can satisfy the RoHS concentration limits and still contain substances that require assessment under REACH.

4. RoHS Uses Homogeneous Material Concentration Limits

RoHS concentration limits generally apply at the homogeneous material level.

This means testing only the concentration of a restricted substance across the total weight of an assembled product may give an incorrect compliance conclusion.

A small component or material can exceed the RoHS limit even when the substance represents only a very small proportion of the finished product.

REACH thresholds depend on the specific legal provision being assessed and should not automatically be interpreted using the same homogeneous-material approach.

5. REACH Includes Chemical Registration Requirements

REACH includes registration obligations for certain substances manufactured or imported into the EU at applicable quantities.

RoHS does not operate a chemical registration system.

Its primary function is controlling specified hazardous substances in electrical and electronic equipment.

6. RoHS Is Connected With CE Marking

RoHS 2 is part of the EU legislative framework associated with CE conformity for electrical and electronic equipment within its scope.

Manufacturers must prepare appropriate technical documentation and issue an EU Declaration of Conformity where applicable.

The CE marking indicates conformity with applicable EU harmonisation legislation, which may include RoHS together with other relevant requirements.

REACH itself does not require CE marking.

This is an important distinction for companies placing electrical products on the EU market.

Can a Product Be Subject to Both REACH and RoHS?

Yes.

Many electrical and electronic products must be assessed against both REACH and RoHS.

Consider an electronic household appliance containing:

Plastic housing
Power cable
Printed circuit board
Solder
Metal components
Rubber parts
Adhesives
Coatings

RoHS may apply to restricted substances within the homogeneous materials used in the electrical equipment.

REACH may separately apply to restricted substances, SVHCs, and other chemical requirements associated with the same materials and components.

Passing RoHS testing therefore does not automatically demonstrate complete REACH compliance.

Similarly, a REACH assessment does not replace applicable RoHS requirements.

REACH vs RoHS Testing

Chemical testing can provide analytical evidence for both REACH and RoHS compliance, but the testing scope is different.

REACH Testing

REACH testing should generally be based on the materials present and the applicable regulatory requirements.

Depending on the product, testing may include substances such as:

Phthalates
PAHs
Restricted azo colorants
Chromium VI
Nickel
Certain heavy metals
Certain flame retardants
Candidate List SVHCs

The appropriate test scope depends on the product and its materials. There is no single laboratory test that verifies every REACH obligation.

RoHS Testing

RoHS testing focuses on the substances restricted under the Directive.

Common analytical techniques can include:

X-ray fluorescence (XRF) screening
ICP-OES or ICP-MS for certain metals
UV-Vis methods for hexavalent chromium where appropriate
GC-MS for certain organic restricted substances

The test method selected depends on the substance and material being analysed.

Is a REACH or RoHS Certificate Required?

This is a common source of confusion.

REACH

There is no universal official REACH certificate for finished consumer products.

Compliance may be supported through:

Supplier declarations
Material information
Chemical composition data
Laboratory test reports
SVHC declarations
Regulatory assessments
Relevant registration or notification information

The appropriate evidence depends on the applicable REACH obligations.

RoHS

RoHS conformity for products within scope is supported through the manufacturer’s conformity assessment and technical documentation.

Relevant records can include:

Material declarations
Supplier documentation
Test reports
Technical documentation
EU Declaration of Conformity

Third-party laboratory reports can provide useful compliance evidence, although a laboratory report alone does not transfer the manufacturer’s legal responsibility for product conformity.

REACH vs RoHS Compliance Documentation

A structured compliance file helps demonstrate how chemical requirements were evaluated.

REACH Documentation	RoHS Documentation
Material and substance information	Bill of materials
Supplier REACH declarations	Supplier material declarations
SVHC declarations	RoHS declarations
Annex XVII assessments	RoHS test reports
Laboratory test reports where relevant	Technical documentation
Registration information where applicable	EU Declaration of Conformity where applicable
Article 33 information where applicable	Applicable exemption information

The exact documentation required depends on the product, business role, and regulatory obligations involved.

Common REACH and RoHS Compliance Mistakes

Assuming RoHS Compliance Covers REACH

RoHS and REACH have separate legal requirements. Electrical products may require assessment under both frameworks.

Treating REACH as a Fixed Substance List

REACH contains different lists and regulatory mechanisms. Annex XVII restrictions, the Candidate List, and Annex XIV have different functions.

Applying RoHS Limits to the Entire Finished Product

RoHS maximum concentration values generally apply to homogeneous materials. Testing or declarations based only on total product weight can produce misleading results.

Using Outdated Supplier Declarations

Chemical regulations and substance lists can change. Documentation should reflect current product materials, suppliers, formulations, and applicable requirements.

Assuming Testing Alone Establishes Full Compliance

Laboratory testing provides analytical evidence for substances included in the test scope.

Complete compliance may also require regulatory assessment, technical documentation, supply-chain communication, declarations, registration, notification, or other obligations.

REACH and RoHS should be assessed according to the product scope, materials, chemical composition, and applicable regulatory requirements.

For electrical and electronic products, the compliance review should identify relevant RoHS homogeneous materials while also checking applicable REACH restrictions and SVHC obligations. Supplier declarations, material records, regulatory assessments, and targeted laboratory testing can then be used to build appropriate compliance evidence.

Keeping REACH and RoHS assessments clearly documented helps ensure that chemical compliance can be verified throughout the supply chain.