By Abhishek Shetty | Thu Aug 24 2023 | 2 min read

Table of Contents

In today’s world, environmental concerns have led governments and international bodies to establish stringent regulations aimed at protecting human health and the environment. Two of the most critical regulations in this domain are RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals).

Although these regulations share a common goal of promoting safer and more sustainable manufacturing, they differ significantly in their scope, compliance requirements, and enforcement.

What is RoHS?

The Restriction of Hazardous Substances (RoHS) directive was introduced to address concerns about hazardous materials used in electrical and electronic equipment (EEE). Enforced within the European Union (EU) and adopted by several other countries, RoHS aims to limit ten hazardous substances found in electronics that pose risks to human health and the environment.

What is REACH?

The Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation is an extensive EU regulation designed to manage chemical substances across all industries. REACH regulates the production, import, and use of chemicals, requiring manufacturers and suppliers to register, evaluate, and, in some cases, obtain authorization for substances that may pose serious risks to health or the environment.

REACH vs. RoHS: Key Differences

REACH vs. RoHS Key Differences.PNG

Restricted Substances Under REACH & RoHS

REACH: Comprehensive Chemical Restrictions

REACH currently regulates 247 hazardous substances as of January 2025, regardless of whether they are used on their own, in mixtures, or as components of finished products. The list is updated regularly by the European Chemicals Agency (ECHA) and includes substances that may cause cancer, genetic mutations, or reproductive harm.

Understanding where RoHS ends and REACH begins is easier when both are supported through a consistent REACH compliance management framework.

RoHS: Targeted Substances in Electronics

RoHS restricts 10 specific substances in electronic and electrical products above certain concentration levels:

  • Cadmium (Cd): < 100 ppm
  • Lead (Pb): < 1000 ppm
  • Mercury (Hg): < 1000 ppm
  • Hexavalent Chromium (Cr VI): < 1000 ppm
  • Polybrominated Biphenyls (PBB): < 1000 ppm
  • Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm
  • Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm
  • Benzyl butyl phthalate (BBP): < 1000 ppm
  • Dibutyl phthalate (DBP): < 1000 ppm
  • Diisobutyl phthalate (DIBP): < 1000 ppm

There are exemptions for certain applications listed in Annexes III & IV of the RoHS directive, but manufacturers must disclose exemptions in compliance declarations.

How to Ensure Compliance with REACH & RoHS

REACH Compliance Steps:

  1. Register substances with ECHA if your company manufactures or imports more than one ton of a substance per year.
  2. Evaluate risks associated with substances and submit a Chemical Safety Assessment (CSA).
  3. Apply for authorization if substances fall under the Substances of Very High Concern (SVHCs) list.
  4. Ensure supply chain transparency by communicating safety information downstream.

RoHS Compliance Steps:

  1. Test and verify that products comply with RoHS-restricted substance limits.
  2. Compile a Technical File, which must include test reports and supplier declarations.
  3. Self-declare compliance by applying CE Marking to compliant products.
  4. Maintain documentation for at least 10 years after placing the product on the market.

REACH + RoHS Compliance Checklist

  • REACH Compliance Checklist
  • Identify substances in BOM >0.1% SVHC threshold
  • Notify customers (Art. 33)
  • Register substances (if >1t/year)
  • Submit SCIP dossiers if needed
  • Apply for authorization if SVHC is in Annex XIV
  • RoHS Compliance Checklist
  • Lab test for 10 restricted substances
  • Collect supplier declarations
  • Maintain CE Declaration of Conformity
  • Compile Technical Documentation
  • Retain files for 10 years post-market

REACH vs. RoHS Enforcement: What Happens if You Don’t Comply?

REACH vs. RoHS Enforcement What Happens if You Don’t Comply.PNG

Beyond the EU: How REACH & RoHS Affect Global Markets

Many other countries have adopted similar regulations to protect consumers and the environment. Examples include:

Manufacturers operating internationally must align compliance strategies across multiple regulatory frameworks to ensure continued market access.

Conclusion: How to Stay Compliant

Understanding the differences between REACH and RoHS is critical for businesses manufacturing or importing products into the EU. Ensuring compliance requires careful monitoring of regulations, proper documentation, and a proactive approach to supply chain management.

Get Expert Help with REACH & RoHS Compliance

Download The Complete Guide to EU REACH Regulation

Download The Complete Guide to ROHS Compliance

RoHS and REACH are not the same compliance problem, and treating them as one creates gaps.

Book a Regilient demo to see how Regilient manages both frameworks from a single supplier data set without duplicating your team's effort.

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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 restricts 10 specific hazardous substances in electrical and electronic equipment, targeting a defined product category. REACH is a far broader regulation covering chemical substances across all industries, including registration, evaluation, and in some cases authorisation requirements. Put simply, RoHS is narrow and substance-specific to electronics; REACH is comprehensive and applies across virtually every manufactured product placed on the EU market.
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.