This is one of the questions we hear most: "I've already done RoHS — why is my customer asking for REACH?" This article lays out the legal basis, limits, obligations and test methods of each.
Different Legal Basis and Scope
- RoHS: based on Directive 2011/65/EU (RoHS 2), amended by delegated Directive (EU) 2015/863 (commonly called RoHS 3), aimed mainly at electrical and electronic equipment (EEE). If your product is not EEE, RoHS in principle does not apply
- REACH: based on Regulation (EC) No 1907/2006, covering nearly all substances, mixtures and articles placed on the EU market — textiles, toys, furniture, packaging, electronics and more. A non-EEE product that falls outside RoHS may still need to satisfy REACH
Different Substances and Limits
RoHS restricts 10 substances, with limits applied at the "homogeneous material" level:
- Lead (Pb), mercury (Hg), hexavalent chromium (Cr6+), PBB and PBDE: each no more than 0.1% (1000 ppm)
- Cadmium (Cd): no more than 0.01% (100 ppm)
- Four phthalates (DEHP, BBP, DBP, DIBP): each no more than 0.1%, added by (EU) 2015/863 and applying to most products from 22 July 2019
REACH is broader, with three main parts:
- SVHC Candidate List: now over 240 substances, updated by ECHA roughly twice a year (refer to ECHA for the current count). When an article contains an SVHC above 0.1% (w/w), suppliers must pass information to downstream customers and consumers under Article 33
- Annex XVII restrictions: specific limits on listed substances — for example entry 51 on phthalates in toys and childcare articles, entry 63 on lead in jewellery, entry 43 on azo dyes
- Notification duties: where an article contains an SVHC above 0.1% and volumes exceed 1 tonne per year, notification to ECHA is required under Article 7(2); in addition, under the Waste Framework Directive, articles containing SVHCs must be reported to ECHA's SCIP database
A key distinction: RoHS is a limit-based requirement — exceed it and the product fails. REACH SVHC is an information-based obligation — exceeding 0.1% does not necessarily bar sale, but triggers duties to inform and notify.
Test Methods and Timelines
- RoHS: test methods follow the IEC 62321 series — typically XRF screening first, then ICP-OES, GC-MS and similar methods for quantitative confirmation where screening is inconclusive; phthalates by GC-MS. Typical turnaround is about 3-5 working days
- REACH SVHC screening: screened item by item against the latest SVHC list using several analytical methods, typically about 5-7 working days — more complex materials and more components mean longer timelines
These are typical reference timelines; rush service and the number of split samples affect actual time and cost. Pricing depends on the number of materials, since testing is split by material or component — more parts means more test points.
A Typical Scenario
A USB cable bound for the EU: RoHS testing finds DEHP above the limit in the PVC jacket — an outright failure. At the same time, a plasticiser or flame retardant in the cable may be an SVHC candidate; the level may not trigger a restriction, but the customer asks for an SVHC declaration. If the cable is sold as an accessory to a children's toy, REACH Annex XVII entry 51 on phthalates may also apply. Such issues usually arise from upstream formulation changes, so companies need a supplier change-notification process rather than testing once before shipment.
Practical Recommendations
- First confirm whether the product is EEE and thus within RoHS scope
- Regardless of RoHS scope, assess REACH compliance for EU exports
- After each ECHA SVHC list update, re-check products using plastics, coatings, rubber, printing inks and solder
- Require substance declarations or test reports from key material suppliers, and trigger reassessment when materials or processes change
- RoHS compliance also requires a technical file and an EU Declaration of Conformity (as part of the CE declaration)
Frequently Asked Questions
Q: Does having RoHS mean I satisfy REACH? A: No. The legal basis, substance lists and type of obligation differ, so neither substitutes for the other; electrical and electronic products exported to the EU generally need both assessed.
Q: If an SVHC is above 0.1%, can't I sell the product? A: Not necessarily. Candidate List substances are not banned in themselves, but above 0.1% you must meet information and notification duties. Whether a ban applies depends on whether the substance is also on REACH Annex XVII or the authorisation list.
Q: How often should reports be refreshed? A: There is no fixed validity, but the SVHC list updates about twice a year and customers and platforms usually ask for recent reports; retest when materials or processes change.
If you have a specific product to assess for RoHS and REACH, send us the bill of materials and material descriptions and we'll help determine which tests you need.