RoHS, REACH, and PPWR often come up together in export compliance discussions, and many companies end up conflating the three. This article does a systematic comparison to help you clearly understand what each one covers and what companies need to do for each.
Comparing the Core Focus of Each Regulation
- RoHS (Restriction of Hazardous Substances): a fixed restricted substance list (currently 10 substances), specifically targeting electrical/electronic products, and one of the prerequisites for a product to carry the CE mark
- REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals): a scope far broader than electrical/electronic products, covering nearly all products sold in the EU, centered on the continuously and dynamically updated SVHC list (currently over 200 substances)
- PPWR (Packaging and Packaging Waste Regulation): doesn't focus on the product's own chemical safety — it focuses on packaging material recyclability and reduction requirements, applying to the packaging of nearly all products
Differences in Regulated Subject Matter
RoHS only covers electrical/electronic products; REACH's scope is extremely broad — textiles, toys, everyday goods, and electronics can all be affected; PPWR steps entirely outside the "product itself" category, focusing specifically on packaging materials. This means even if a product's RoHS and REACH compliance is fully in order, non-compliant packaging materials under PPWR can still create a compliance problem.
Differences in Update Mechanisms
RoHS's restricted substance list is relatively stable, having gone through a few major version upgrades historically (from an original 6 substances to the current 10); REACH's SVHC list, by contrast, is continuously and dynamically updated, typically evaluated annually for new additions — companies can't "test once and be covered forever"; PPWR, as a relatively newer regulatory framework, is still being refined and rolled out in stages, with specific implementation details and timelines needing ongoing tracking against the latest official announcements.
Separate Response Mechanisms Companies Need to Build
- For RoHS: confirm which version currently applies to your product (currently RoHS 3.0, 10 restricted substances) and ensure test reports cover all of them
- For REACH/SVHC: maintain a materials ledger and track list updates, paying particular attention to plastic parts, coatings, and electronic components that commonly involve SVHC substances
- For PPWR: factor in recyclability and reduction requirements at the packaging design stage, rather than retrofitting after the product is finalized
A Common Misconception: Assuming One Covers All Three
This is the easiest trap to fall into — companies often assume that having "already done RoHS testing" means their chemical compliance is fully covered, but RoHS only covers 10 specific substances and is an entirely separate list from REACH/SVHC. Both need to be confirmed independently — neither substitutes for the other.
Frequently Asked Questions
Q: Can these three regulations be tested together in one go? A: Not entirely — while RoHS and REACH/SVHC testing may use the same batch of samples, the substance lists and reference standards differ, generally requiring separate test item applications. PPWR is an entirely different dimension (packaging design) and doesn't involve chemical testing of the product itself.
Q: With limited resources, which regulation should smaller companies prioritize? A: If the product is electrical/electronic, RoHS is the most basic threshold and must be secured first; REACH/SVHC should be tracked in parallel, especially for products with significant plastic components; PPWR can be planned alongside the packaging design cycle without urgent immediate action, though it's worth continuously tracking the official timeline.
If you'd like a systematic review of your product's compliance status across these three regulations, reach out to us for a comprehensive assessment.