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RoHS vs REACH: What's the Difference?

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

  1. First confirm whether the product is EEE and thus within RoHS scope
  2. Regardless of RoHS scope, assess REACH compliance for EU exports
  3. After each ECHA SVHC list update, re-check products using plastics, coatings, rubber, printing inks and solder
  4. Require substance declarations or test reports from key material suppliers, and trigger reassessment when materials or processes change
  5. 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.