RoHS vs. REACH Compliance Explained

The manufacturing industry is forever changing with regulations and rules. One that we are seeing more often is RoHS and REACH Compliance. These can easily be mistaken as the same or very similar. So this post will distinguish the difference between the two.

RoHS Compliantrohs

RoHS stands for Restriction oHazardous Substances. RoHS can be pronounced “Ar, Oh, Ach, Es” or like “rose.”

This is a European Union directive rather than a regulation, meaning it is an instruction for those involved, but there isn’t a enforcer or regulator of how the results are achieved. The sole purpose is to address the global issue of consumer electronics waste. With the forever evolving technology world, many electronics are disposed and end up in landfills which end up causing environmental and human health hazards. This directive pertains to manufacturing of various types of electronic and electrical equipment without the use of six different hazardous materials:

  1. Lead (Pb)
  2. Mercury (Hg)
  3. Cadmium (Cd)
  4. Hexavalent chromium (Cr6+): Used in chrome plating, chromate coatings, and primers
  5. Polybrominated biphenyls (PBB): Flame retardant in plastic
  6. Polybrominated diphenyl ether (PBDE): Flame retardant in plastic

According to RoHSGuide.com, the maximum levels in non-exempt products are 0.1% or 1000 ppm (except for cadmium and mercury, which are limited to 0.01% or 100 ppm) by weight. These limits do not apply to the weight of the finished product, or even to a component, but to any single substance that could, theoretically, be separated mechanically—for example, the sheath on a cable or the tinning on a component lead.

The directive applies to the following types of equipment:

  1. Large household appliances.
  2. Small household appliances.
  3. IT & Telecommunications equipment (although infrastructure equipment is exempt in some countries)
  4. Consumer equipment.
  5. Lighting equipment—including light bulbs.
  6. Electronic and electrical tools.
  7. Toys, leisure, and sports equipment.
  8. Medical devices (exemption removed in July 2011)
  9. Monitoring and control instruments (exemption removed in July 2011)
  10. Automatic dispensers.
  11. Semiconductor devices

Regardless of where the product is made in the European Union or imported, it is the responsibility of the company who puts the product on the market to comply with the directive. Therefore many companies will pass down the directive to their manufacturing suppliers and subcontractors in order to maintain full compliance throughout the manufacturing process.

REACH Compliancereach

REACH stands for:

Registration: Chemical producers are required to register safety data for all chemicals produced.

Evaluation: Experts from member states and the European Agency evaluate safety data for higher volume chemicals and other chemicals of concern.

Authorization: Chemicals that are of “very high concern” are to be phased out and replaced with safer alternative chemicals.

Restriction of Chemicals: Chemicals may be completely banned or some uses of the chemicals can be restricted.

This is a European Union regulation. The sole purpose of REACH is to address the production and use of chemical substances, and their potential impacts on both human health and the environment. REACH requires all companies manufacturing or importing chemical substances into the European Union in quantities of one tonne or more per year to register these substances with European Chemical Agency (ECHA). Manufacturers, importers and also their customers are required to communicate information on chemicals throughout the supply chain in order to be aware of information relating to health and safety of the products supplied.

Some of the chemicals that are of “very high concern” include:

  • Carcinogens
  • Mutagens
  • Reproduction toxins
  • Persistent, bio-accumulative, and toxic chemicals

Difference Between RoHS and REACH

Therefore the main difference between RoHS and REACH is that RoHS bans substances that are present in electrical equipment that is within the directive. REACH, however, pertains to all chemicals including those used to make a product. This can include materials, solvents, paints, chemicals, and more. We hope this allows you to better understand these regulations and how you can comply.

Vista Industrial Products fabricates sheet metal, machined and welded parts with Reach and RoHS compliant requirements.  If you have questions, be sure to leave them in the comment box below. If you have metal parts that need to be fabricated and require RoHS or REACH, please send us a Request For Quote!

63 thoughts on “RoHS vs. REACH Compliance Explained

  1. Hi! Thank you for the article, very clear.
    However, I have a question: products which are under RoHS directive, do they also have to pass REACH certification ? Example, mobile phones manufacturers have to apply for both regulations, or only for RoHS?

    Thank you in advance

    Regards,
    Vic

    • RoHS and REACH interact in a complex and complimentary way. The simplest answer would be that if a product is RoHS compliant, it may not be REACH compliant, and vice-versa, but a product may be required to meet both regulations. RoHS deals specifically with the electronics industry, while REACH is similar in design, but broader in focus.

      In the example of a mobile phone, our understanding is that the device will have to conform to both regulations, though there is no “application” involved.

      • Question… if you manufacture metal products how would either of these apply? Possibly REACh, but I don’t think RoHS. RoHS pertains to electrical components. How does sheet metal fall in that category?

        • Hi Ramie,

          This is a great question. Being that we are a metal fabricator, RoHS and REACH apply to us based upon the products we build for companies. For example, we fabricate a lot of medical devices or components of medical devices for medical device companies that sell their product overseas. Many times the products we build will require hardware or a finish that needs to be RoHS and/or REACH compliant. Therefore, we have to make sure we use hardware during the assembly process that meets these requirements and have the right documentation for verification and compliance. Same goes for the metal finishing, which for example could be chemical film, that needs to have certain chemicals that meet these requirements and have the documentation to support it because of whatever the end product is. I hope this answers your question.

  2. We have development board already build and manufacturer is A.L Electronics in Israel. One of the worst manufacturer ever.
    We cannot get any ROHS/REACH information from them. Do yo have any suggestion on how to proceed in sending the boards to Europe?

    • Hi Anthony,

      Thank you for your response. It is important to note that not all manufacturers are RoHS/REACH compliant. It is crucial to have a specific RoHS/REACH compliant company manufacture your boards that will be going to Europe. So in this case, the company in Israel may not be compliant, which is why they cannot provide you with the information you need. On the other hand, if they are compliant, it is best to notify the manufacturer BEFORE PRODUCTION that the parts need to be compliant so the parts can be manufactured properly and they are able to provide you with the information you need. If parts are not identified as being RoHS/REACH compliant beforehand, they may not be be compliant.

      If in the future you require metal fabrication from a RoHS/REACH compliant manufacturer, please contact us and we will be happy to accommodate your needs!

  3. If the product is complied with ROHS and not complied with REACH, then what is the situation of the product, is that allowed in EU market?

  4. Britney.. well done!! Finally… very good and simple explanation. Best explanation!!

    I will take this opportunity to ask you something then. For the Australian market, my product is a tooth brush with rechargeable (via usb cord) lithium battery operated, is there something similar that I need to test or complies for? if not, do I need both RoHS & REACH?

    Thanks in advance!!

    • Hi Tony,

      Thank you for your comment! Since RoHS and REACH generally apply to the European market, the Australian market may require something completely different with your product. I’d recommend doing some research on Australian regulations first to see if RoHS and REACH are applicable.

  5. Pingback: The Environmental Health & Safety Tightrope | Caelus Green Room

  6. How does a company become compliant? Are there forms to fill out and inspections required? Or is it left up to the company to examine their processes, chemicals, etc., and then ‘declare’ themselves to be a compliant supplier?

    • Hi Larry,

      For REACH, you would have to register on a website usually requested by your end customer, and list the restricted chemicals you use in the manufacturing process. For RoHS, it is up to the company to certify that their end product is compliant. The end customer may want a certificate of process signed, but that is up to the customer on what they request for proof of conformance.

  7. Hi, thank you for the very informative article. With regards to ROHS and REACH, I believe they are applicable to the end product. Therefore, for a product to be compliant with ROHS and REACH, either all the materials (raw materials, additives, release agents etc) used in the construction of the product is compliant with both standards or the final product needs to be tested for compliance. Am I right?

  8. Hi, A company in the UK imports metal alloys to fabricate into components used in other industries such as aerospace, energy, medical, etc. Some of these alloys contain Nickel which I see is on the list. Do they have to register, notify and communicate? Thanking you in advance

  9. We are doing imitation jewelry and want to sell to EU.Our products are mainly made by stainless steel,silicone,also some are plated stainless steel with gold or silver colour.Can you advise us which compliance are required.

    Thanks!

    • Hi Ellis,

      I am not familiar on what imitation jewelry is, but I’ll try to answer your question the best I can. RoHS is specific to electronic products, so I would recommend reviewing the REACH regulations to see if your products will comply.

  10. Hi, i would like to ask, if a product is REACH compliance, is it still need to test for RoHS? or is the REACH can cover RoHS requirement?

    • Hi JQ,

      It’s important to keep in mind that being REACH compliant does not necessarily mean you are covered for RoHS. However, it is possible to be both and it all depends on the product. Please reference each directive specifically based on your product.

  11. Hi, nicely put. I have a question. Once a company is REACH or RoHS compliant, how long is it valid? Meaning, do we have to renew the certificate, if there are no changes in the components?

  12. Does the substances like Cd,Pb,Hg which are limited in RoHS are also listed in REACH .If yes then why we need RoHS if REACH is enough for limiting hazardeous substances.

  13. Hi, i have some question on phthalate substances mentioned in RoHS and Reach regulation. hope you aware of RoHS2 recently amendment (EU) 2015/863, where 4 more hazards restriction (phthalates-(DIBP),(BBP),(DBP),(DEHP)) is added to the existing 6 substances . but if you see the same phthalates-(DIBP),(BBP),(DBP),(DEHP) is already listed in Reach candidate list. can you tell me difference between the RoHS and Reach phthalate listed. so if reach certification is good enough for RoHS declaration of conformity.

  14. Hi, thanks for the article. I would like to know what happens if the products are not REACH compliant. Can I still sell them ? I understand the only requirement is to say it to customers if they request it…. But the report can still state it is not compliant. Is that right ?
    Thank you

    • Hi Po,

      It is our understanding that as long as you disclose that the products are not REACH compliant, it is up to the buyer whether or not to purchase REACH compliant parts. It also depending on the country they are in, and if their products need to be REACH compliant.

      • Not sure you can be REACH compliant, unless you mean that you publish a list of chemicals used in your products. The lists in REACH change and the banned and permitted uses change too. RoHS is different, with a fixed list with which one can comply.

  15. Dear Sirs,
    we produce equipment for extracorporeal circulation (medical devices).
    Article 7.2 and Article. 33 of the Reach Regulation providing for obligations at a time when the content of substances exceed the percentage of 0.1%.
    This limit is to be understood based on the weight of the SVHC substance on the final weight of the entire article that will be placed on the market or to the weight of the SVHC substance of the single component (such as a PVC rod) produced by one of our supplier and forming part of ‘final article itself?

    • Steel on its own will be REACH compliant (see the composition details on the spec for the grade you are using.
      You should detail the type of steel you are using, how much and where.
      It is possible that the lead content of some steels will be restricted in the future but at the moment, there are no alternatives
      Any coatings you are using with the steel should be checked as many fall under REAC

  16. Hi, for products like electric pumps, to blow the air mattress mattress (medical device), if the product is ROHS Certified (with Declaration of conformity) do you think one should need REACH Certification too?

      • If yo make the pumps, check the documentation of chemicals supplied to you, if the pumps come complete, ask your supplier if they used any hazardous chemicals in the manufacture, then include details of any such in your documentation to your customers

    • REACH requires that if you are using a listed chemical that is hazardous you must declare it, there is not such thing as ‘REACH compliance’ in that you can’t say your product is compliant, only that you have listed any of the substances that carry a restriction and all details for safe handling and disposal.
      If any of your suppliers are using a REACH chemical (glues, paints, gasses), they should notify you and there will be a chemical registration document with yellow or red icons

  17. Do you know if there is any tag or graphic, like those showed above, that can be applied to product labels or even to their (M)SDS that are conforming to international regulations and free from any proprietary right?

  18. Hi,
    great explanation.
    Correct me if I’m wrong: To use the “Rohs compliant” logo on a product it is not necessary to undergo any authorisation process, as it is sufficient that the manufacturer certifies its compliance.
    To import monofilament (made with REACH/RoHS certified raw materials) from a non-EU country to EU,
    – RoHS it is not applicable
    – REACH: we can declare that the product is compliant based on the material Data Sheet.
    Thank you.

    • RoHS relates specifically to electronic goods, the assembled products for sale must be compliant and self certified (non compliance on inspection leads to heavy fines or prison terms)
      REACH is also self certified, facing similar penalties.
      In both cases, you need product documentation to component level showing compliance

  19. Hello,

    We have a customised SECC plate (which is cutted and bended) in our product.
    We got one vendor who mentions that they can provide SECC plates and they have REACH SVHC certified by SGS, but they don`t have ROHS. So making final product from such customised SECC would cause any problem if our market is US,Europe, and UK?

    • No, one test won’t do. They are different regulations. RoHS means you have to check every component to make sure it is compliant (best done at the design stage), RoHS has been superseded by the CE mark in many cases, so you should also check for this.
      REACh is a chemical declaration. If any supplier is using or supplying you with dangerous chemicals you will find a hazard from and the relevant yellow pictograph and description on their documentation and packaging. Look at the Chempro website as a good source of info. Unless you make chemicals, the info should be passed down through your supply chain.
      The REACh list is updated regularly, so you will have to keep monitoring it

  20. HI NEED YOUR HELP ,I UNDERSTAND THAT REACH AND ROHS complementary to each other meaning ROHS are for electronic and REACH FOR MATERIALS ,HOWEVER DOES THE MATERIAL OF THE ELECTRONIC PARTS CAN BE ACCORDING TO REACH AS WELL OR ONLY ROHS? WHAT ABOUT CEPA (CANADIAN) ,ARE YOU FAMILIAR WITH THIS REGULATION ,WHAT IS THE DIFFERENCE BETWEEN IT AND ROHS/REACH ?

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