RoHS vs REACH: What’s the Difference?

RoHS restricts 10 specific hazardous substances in electrical and electronic equipment. REACH regulates a much broader list of chemicals, currently 253 Substances of Very High Concern, across nearly all product categories, not just electronics. Most electronics manufacturers shipping into the EU need to comply with both.

RoHS vs REACH at a Glance

Both are EU laws. Neither is optional if you’re shipping hardware into the EU. And neither one covers what the other does, which is exactly where teams get into trouble.

What Does RoHS Cover That REACH Doesn’t?

RoHS is narrow, and that’s the point. It applies only to electrical and electronic equipment, and the directive text itself sets a hard concentration limit for exactly 10 substances: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and the four phthalates added in 2019. The limit is 0.1% by weight in any homogeneous material (0.01% for cadmium), measured at the level of an individual material inside a component, not the finished product as a whole. A cable jacket, a solder joint, and a plastic housing are each checked separately.

That specificity is what makes RoHS testing manageable. A lab runs XRF screening or IEC 62321 wet-chemistry testing, checks 10 substances, and issues a Declaration of Conformity. It doesn’t matter how much of the restricted substance you’re shipping in total. A single connector over the limit fails the same way a whole shipment would.

What RoHS doesn’t do is regulate chemicals in general. It has nothing to say about a flame retardant that isn’t PBB or PBDE, a solvent used in manufacturing, or a coating chemical that never made anyone’s short list of 10. It also doesn’t touch registration volumes, safety data sheets, or downstream notification duties. RoHS is a substance-in-product test, full stop. Pass it, and you’ve proven exactly one thing about your product: these 10 substances are under the limit. That gap, everything RoHS was never built to check, is where REACH picks up.

What Does REACH Cover That RoHS Doesn’t?

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals, and it covers exactly what the name says: chemicals, in nearly any product category, not just electronics. It has three separate mechanisms that RoHS doesn’t.

First, registration. Any company manufacturing or importing a substance into the EU above one tonne per year has to register it with ECHA, with safety data covering its hazards. This is the mechanism that gives REACH its name, and it has nothing to do with electronics specifically. A chemical distributor selling solvent to a coatings plant is just as subject to it as a component manufacturer.

Second, the SVHC Candidate List: the 253 substances mentioned above, which trigger a communication duty rather than an outright ban. If any listed SVHC shows up above 0.1% by weight in an article you’re placing on the EU market, you have to notify your customers, and in some cases ECHA itself, within 45 days of it appearing on the list. This is the mechanism that catches most electronics companies off guard, because it applies retroactively. A part that was fine when you qualified it can become a notification obligation the moment ECHA adds a substance found in it.

Third, the Authorisation and Restriction lists (Annex XIV and Annex XVII). Authorisation means a substance can’t be used at all without specific permission from the European Commission, granted case by case. Restriction is broader and blunter: certain uses of a substance are banned outright, across every industry, regardless of concentration thresholds that apply elsewhere in REACH. Both sit above and beyond the SVHC list in severity, and both apply whether or not the product in question is electronic.

None of this is limited to electronics. Packaging, textiles, furniture, toys, cosmetics, and yes, EEE, all fall under REACH if they contain the wrong chemical at the wrong concentration. A company that only ships PCBAs still has REACH exposure through solder flux, conformal coatings, adhesives, and cable insulation, none of which RoHS’s 10-substance list touches directly.

Do You Need Both?

Yes. This is the part most competitor articles mention in passing and then move on from, which is exactly how teams end up confused.

Several substances restricted under RoHS also happen to be on REACH’s SVHC list or its Annex XVII restriction list. Lead compounds, certain cadmium compounds, and some of the phthalates show up in both regulations. That overlap is real, but it’s also the trap. Passing RoHS testing on your 10 substances doesn’t mean you’ve cleared REACH, because REACH’s list is 25 times longer and covers substances RoHS has never restricted: certain PFAS compounds, specific brominated flame retardants outside the PBB/PBDE family, and various phthalates beyond the four RoHS names.

Two products can both carry a clean RoHS certificate and still differ completely on REACH exposure, because REACH cares about every material in the product, not just the ones RoHS happens to test for. A supplier switching to a cheaper flame retardant during a component shortage might stay fully RoHS compliant while introducing an SVHC that triggers a REACH notification obligation nobody caught.

Here’s the part that trips up procurement teams the most: RoHS compliance is checked once, at qualification, and stays true as long as the bill of materials doesn’t change. REACH compliance can change underneath you even when your BOM stays exactly the same, because ECHA keeps adding substances to the Candidate List. A component that cleared REACH screening cleanly two years ago can become an SVHC-containing part today, with zero design changes on your end. That’s not a hypothetical. It’s the direct result of a list that keeps growing, several updates a year, every one of them a chance for a previously clean component to need a fresh look.

This is also where the paperwork gets confusing for buyers. A RoHS Declaration of Conformity is a standard, well-understood document, one page, one signature, one clear pass/fail. REACH compliance doesn’t have an equivalent single certificate. It’s closer to an ongoing screening process against a list that changes, tied to a communication duty that depends on what’s actually in your BOM at any given moment. A supplier who hands you a RoHS certificate and calls the compliance conversation finished isn’t being dishonest. They’re just answering half the question.

How This Affects Your Manufacturing Partner Selection

This is where the RoHS/REACH gap turns into an actual shipment problem, and it’s worth asking your manufacturing partner about directly before you’re mid-production, not after customs flags something.

A few things worth asking a potential EMS or ODM partner:

• Do they check the BOM against the current SVHC Candidate List, or only against RoHS’s 10 substances? Plenty of factories run RoHS screening as a matter of course and never touch REACH at all.
• How do they handle a component substitution mid-production? Shortages force substitutions constantly, and a substitute part can quietly introduce an SVHC that the original never had.
• Can they trace compliance data down to the homogeneous material level, or only at the component level? A supplier declaration that just says “RoHS compliant” on a connector doesn’t tell you what’s in the plastic housing versus the plating versus the wire itself.
• Do they track SVHC list updates as part of ongoing production, or only at initial qualification? ECHA adds to the list multiple times a year. A BOM that was clean at DFM review can fall out of compliance eighteen months later without anyone touching the design.
• What documentation do they hand you for customs, and does it distinguish RoHS conformity from REACH Article 33 notification? These are two different documents answering two different legal questions, and customs officials in different EU member states have gotten stricter about seeing both.

This kind of check belongs in the design-for-manufacturability conversation, not as a last-minute scramble before a container ships. A DFM review that flags a questionable material choice early is a lot cheaper than a rejected shipment sitting at a port, and it’s usually a small addition to the review your partner is already doing on fit, tolerance, and assembly risk. It’s also worth asking how a partner handles UL certification and other product safety marks alongside RoHS and REACH, since buyers tend to request all three together during due diligence even though the underlying regulations don’t overlap much.

None of this needs to slow down a quote. Most of it is a five-minute conversation with a sourcing engineer who actually knows the answer, versus finding out from a customs broker three weeks after a shipment was supposed to land.

At Titoma, our sourcing and DFM process checks BOM materials against both the RoHS restricted list and the current SVHC Candidate List before a design moves into production, not after a customs hold surfaces the gap. It’s a small step during quoting that avoids a much more expensive one later.