By Abhishek ShettyPublished: 2 min read

Table of Contents

RoHS and REACH are both European Union chemical-related compliance requirements, but they are not the same regulation. RoHS primarily restricts specific hazardous substances in electrical and electronic equipment, while REACH is a broader chemicals regulation covering the registration, evaluation, authorisation and restriction of chemical substances.

For manufacturers of electrical and electronic products, the two requirements can overlap. However, compliance with RoHS does not automatically mean compliance with REACH.

The practical question for manufacturers is therefore not simply whether a product is RoHS compliant or REACH compliant. It is whether the product, its components, materials and supply chain information have been assessed against each requirement that applies.

Comparrison of RoHS vs REACH at a Glance


RoHS

REACH

Full name

Restriction of Hazardous Substances

Registration, Evaluation, Authorisation and Restriction of Chemicals

Primary purpose

Restrict specified hazardous substances in electrical and electronic equipment

Manage risks from chemical substances and protect human health and the environment

Main focus

Restricted substances in EEE

Chemical substances, mixtures and substances in articles

Applies primarily to

Electrical and electronic equipment within scope

Manufacturers, importers, downstream users and suppliers, depending on the obligation

Key mechanisms

Substance restrictions, exemptions and conformity assessment

Registration, authorisation, restriction and supply-chain communication

Relationship

Product-focused substance restrictions

Broader chemical regulatory framework

Can one replace the other?

No

No

REACH restrictions can apply to substances on their own, in mixtures or in articles, while REACH also creates other obligations depending on the substance, use and role of the company in the supply chain.

What Is the Difference Between RoHS and REACH?

The biggest difference is what each regulation is designed to control.

RoHS focuses on restricted substances in electrical and electronic equipment

RoHS, established through Directive 2011/65/EU and its amendments, restricts specified substances in electrical and electronic equipment.

For manufacturers, the compliance question is essentially:

Does the electrical or electronic equipment contain restricted substances above the applicable limits, taking into account any applicable exemptions?

The assessment therefore involves the product, its components, materials and the evidence supporting the material composition.

For a detailed explanation of RoHS applicability, see Scope of EU RoHS Compliance.

Does REACH have a broader chemicals focus

REACH applies to chemical substances across their lifecycle and includes mechanisms such as registration, evaluation, authorisation and restriction.

Depending on the company's role and the substance involved, REACH obligations can apply to substances, mixtures and articles.

For articles containing Candidate List substances, REACH can also create supply-chain communication obligations. ECHA states that suppliers of relevant articles must provide information when a Candidate List substance is present above 0.1% by weight, subject to the applicable requirements.

This is why a manufacturer cannot treat RoHS and REACH as interchangeable requirements.

Are RoHS and REACH the Same?

No. RoHS and REACH have different scopes, mechanisms and compliance obligations.

They can address some of the same substances, but they regulate them through different frameworks.

For example, a substance may be restricted under RoHS for electrical and electronic equipment while a different REACH obligation may apply to the same substance based on its use, concentration, article status or position in the supply chain.

The presence of an overlapping substance therefore does not make the two assessments identical.

Does RoHS Compliance Mean REACH Compliance?

No. RoHS compliance does not automatically establish REACH compliance.

A manufacturer can meet the applicable RoHS substance restrictions and still need to assess separate REACH obligations.

The reason is simple: the regulations ask different questions.

RoHS asks:

Are the applicable restricted substances in the EEE within the relevant limits or covered by an applicable exemption?

REACH may require manufacturers or other supply-chain actors to consider:

What substances are involved, what obligations apply to the company's role, and are registration, authorisation, restriction or communication requirements triggered?

REACH restrictions can apply to substances, mixtures and articles, and its Candidate List can trigger specific obligations for substances in articles.

When Do Manufacturers Need to Consider Both RoHS and REACH?

Manufacturers of electrical and electronic equipment may need to consider both when their products fall within the relevant RoHS scope and their materials, substances or supply-chain relationships create applicable REACH obligations.

A practical assessment can therefore involve two parallel questions:

RoHS assessment

  1. Is the product within RoHS scope?
  2. Which restricted substances are relevant?
  3. Do applicable concentration limits need to be assessed?
  4. Are any exemptions relevant?
  5. Is sufficient compliance evidence available?

REACH assessment

  1. Which substances or articles are involved?
  2. What is the company's role in the supply chain?
  3. Are registration obligations relevant?
  4. Are authorisation or restriction requirements relevant?
  5. Are Candidate List communication or notification obligations triggered?

REACH registration obligations, for example, can apply to companies manufacturing or importing substances above the applicable one-tonne-per-year threshold, subject to the regulation's provisions and exemptions.

This is why manufacturers should assess the two regulations separately even when the same product is being evaluated.

RoHS vs REACH: How the Supply-Chain Data Differs

One of the biggest practical differences for manufacturers is the type of information needed from suppliers.

For RoHS, manufacturers commonly need information that helps establish whether components and materials meet the applicable substance restrictions.

For REACH, the information required can depend on the substance, article, use and the company's role in the supply chain.

For articles containing Candidate List substances, suppliers may have communication obligations, and producers or importers can need information about substances present in their articles.

This means a single generic supplier declaration may not answer every compliance question.

A better approach is to maintain regulation-specific evidence linked to the relevant component, material and product.

Can the Same Supplier Data Support Both RoHS and REACH?

Yes, some supplier information can support both assessments, but it should not automatically be treated as sufficient for both.

A supplier may provide material composition information that helps a manufacturer evaluate multiple requirements.

However, each regulation has its own scope, thresholds, definitions and obligations.

The manufacturer should therefore determine:

  • What information was actually provided
  • Which component or material it covers
  • When the information was issued
  • Which regulatory requirement it supports
  • Whether additional information is required

This avoids a common compliance mistake: treating one supplier declaration as a universal compliance certificate.

For the separate issue of evaluating the reliability of supplier declarations and when testing may be necessary, see RoHS Compliance: When Declarations Pass but Testing Fails.

RoHS Exemptions and REACH Restrictions Are Different

The terms exemption and restriction should not be treated as interchangeable.

RoHS contains specific exemptions that can permit certain restricted substance uses under defined conditions.

REACH uses different mechanisms, including restrictions under Annex XVII and authorisation requirements for certain substances. ECHA describes REACH restrictions as measures that can limit or prohibit the manufacture, placing on the market or use of substances, including certain substances in articles.

Therefore:

A RoHS exemption does not automatically create a REACH exemption.

If a manufacturer relies on a RoHS exemption, it should still assess whether separate REACH obligations apply.

For RoHS-specific exemption requirements, see RoHS Directive Regulations & Exemptions.

How Manufacturers Can Manage RoHS and REACH Together

The most effective approach is not to create one generic compliance record labelled "RoHS/REACH."

Instead, manufacturers can maintain a connected compliance structure:

Supplier

↓

Component

↓

Material / Substance Information

↓

Regulatory Assessment

↓

Product

↓

Compliance Evidence

This allows the same underlying material information to support multiple regulatory assessments while keeping each regulation's requirements distinct.

For manufacturers managing large product portfolios, this becomes particularly important because supplier information can change and the same component may appear in multiple products.

RoHS vs REACH: What Manufacturers Should Remember

The key distinction is straightforward:

RoHS is primarily concerned with restricting specified hazardous substances in electrical and electronic equipment.

REACH is a broader chemicals regulation covering mechanisms including registration, evaluation, authorisation and restriction, with obligations that can apply differently depending on substances, articles, uses and supply-chain roles.

The two frameworks can overlap, but one does not replace the other.

For manufacturers, the practical objective is to determine which requirements apply, collect the right supplier and material information, assess each regulation correctly and maintain evidence that can be traced back to the relevant products and components.

Conclusion

RoHS and REACH overlap in some areas, but they solve different regulatory problems.

RoHS focuses on restricted substances in electrical and electronic equipment. REACH provides a broader framework for managing chemical substances and related supply-chain obligations.

For manufacturers, the safest approach is not to assume that compliance with one means compliance with the other.

Instead, assess RoHS and REACH separately, connect the underlying product and supplier data, and maintain traceable evidence for each applicable requirement.

That approach gives compliance teams a clearer view of what has been assessed, what evidence supports the decision and where additional supplier information may still be required.

Topics

RoHSREACHEuropean Union Regulations

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RoHS vs REACH: Understanding the Key Differences in EU Compliance

What is the main difference between RoHS and REACH?
RoHS primarily restricts specified hazardous substances in electrical and electronic equipment, while REACH is a broader chemicals regulation covering mechanisms such as registration, evaluation, authorisation and restriction.
Do companies need to comply with both RoHS and REACH?
Yes. Any manufacturer or importer placing electrical and electronic equipment on the EU market must satisfy RoHS substance restrictions and REACH chemical obligations simultaneously. Passing one does not exempt a product from the other, since they cover different substances, different thresholds, and different documentation requirements.
What are the compliance steps for REACH versus RoHS?
REACH: register substances with ECHA above one tonne per year, complete a Chemical Safety Assessment, apply for authorisation if an SVHC is involved, and ensure supply chain transparency through Article 33 disclosure RoHS: test and verify products against the 10 restricted substance limits, compile a technical file with test reports and supplier declarations, self-declare compliance via CE marking, and retain documentation for at least 10 years
What documentation does each regulation require?
REACH requires substance registration records, SVHC customer notifications under Article 33, and SCIP dossiers where applicable. RoHS requires a technical file containing test reports, supplier declarations, and a CE Declaration of Conformity. Manufacturers managing both frameworks typically need two parallel documentation trails, since the underlying substance data rarely maps one-to-one between the two regulations.
What happens if a company fails to comply with RoHS or REACH?
Non-compliance under either regulation can result in product bans, recalls, fines, and enforcement action by national authorities across the EU. Because RoHS and REACH are enforced independently, a single product can face two separate enforcement actions if it fails both frameworks at once, compounding the commercial and reputational impact.
How does Regilient help manufacturers manage RoHS and REACH compliance together?
Regilient's agentic sustainability platform manages both frameworks within a single compliance programme: Automated BOM screening against RoHS substance limits and the REACH Candidate List simultaneously Supplier declaration collection structured to satisfy both RoHS technical file and REACH Article 33 requirements from the same data set SCIP dossier generation and CE marking documentation support Real-time alerts when either the RoHS substance list or the REACH Candidate List is updated This avoids the duplicated supplier outreach that happens when RoHS and REACH are managed as entirely separate programmes.
Is RoHS part of REACH?
No. RoHS and REACH are separate EU regulatory frameworks. They can address some of the same substances, but they have different scopes and obligations.
Does RoHS compliance mean a product is REACH compliant?
No. A product can meet the applicable RoHS requirements while still having separate REACH obligations.
Do electronics manufacturers need both RoHS and REACH?
Potentially, yes. An electronics manufacturer should assess whether its products fall within RoHS scope and whether applicable REACH obligations arise from the substances, articles, uses or supply-chain relationships involved.
Do RoHS and REACH regulate the same substances?
Some substances can be relevant to both frameworks, but the regulations regulate them differently. The fact that a substance appears in both frameworks does not make the compliance assessment identical.
Does a RoHS exemption apply to REACH?
No. A RoHS exemption does not automatically exempt a substance or product from applicable REACH requirements.
Can one supplier declaration prove both RoHS and REACH compliance?
Not necessarily. Supplier information can support both assessments, but manufacturers need to determine whether the information satisfies the specific requirements of each regulation.
What information should manufacturers collect from suppliers?
The information depends on the applicable requirement. Manufacturers may need material composition, substance information, declarations, supporting evidence and other documentation relevant to the specific regulatory assessment.
How does REACH apply to substances in articles?
REACH can create specific obligations for substances in articles, including communication and, in certain circumstances, notification or registration requirements. Candidate List substances above the applicable 0.1% threshold can trigger supply-chain communication obligations.
Should RoHS and REACH compliance be managed separately?
The regulatory assessments should remain distinct, but manufacturers can manage the underlying supplier, component, material and evidence data through a connected compliance workflow.
How can manufacturers manage RoHS and REACH data at scale?
A centralised compliance system can connect suppliers, components, products and regulatory evidence while keeping each regulation's requirements and assessment criteria separate.