RoHS vs. REACH Declarations: Which Do Your Component Suppliers Actually Need to Provide?¶

One of the most common causes of supply chain friction in European manufacturing is the conflation of REACH and RoHS.

It happens every day: A procurement manager emails a supplier asking for a "REACH/RoHS Certificate." The supplier, based outside the EU and confused by the acronyms, replies with a generic letter stating their product is "safe and compliant." The procurement manager files it away. A year later, a market surveillance authority audits the manufacturer, deems the generic letter invalid, and forces a product recall.

While both REACH and RoHS are European regulations designed to protect human health and the environment from hazardous chemicals, their scopes, thresholds, and reporting mechanics are completely different. To secure your supply chain, you must know exactly what to ask for.

Core Difference 1: The Scope of Products Covered¶

RoHS (Restriction of Hazardous Substances) is a "vertical" directive. It applies only to Electrical and Electronic Equipment (EEE). If your product requires electricity or electromagnetic fields to fulfill its primary function, it falls under RoHS. If you are manufacturing wooden furniture, leather shoes, or mechanical bicycles, RoHS does not apply to you.

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a "horizontal" regulation. It applies to virtually every single physical product (referred to as "articles") manufactured in, or imported into, the European Union. Whether you are selling a smartphone, a plastic toy, a textile shirt, or industrial machinery, you are subject to REACH.

Core Difference 2: The List of Substances¶

RoHS restricts exactly 10 specific substances (Lead, Mercury, Cadmium, Hexavalent Chromium, PBBs, PBDEs, and four phthalates). It is a static ban (with specific exemptions).

REACH is vastly more complex. For product manufacturers, the primary concern is the Candidate List of Substances of Very High Concern (SVHCs). As of 2026, there are over 240 substances on this list, and the European Chemicals Agency (ECHA) updates the list twice a year (typically in January and July).

Unlike RoHS, REACH does not necessarily ban these SVHCs in articles. Instead, it creates a "duty to communicate." If an SVHC is present in your product above a specific threshold, you must declare it to your B2B customers, register it in the SCIP database, and provide safe handling instructions to consumers upon request.

Core Difference 3: The Calculation Thresholds¶

This is where supplier declarations usually fail. The calculation methods for the two regulations are fundamentally different.

• RoHS Threshold: Calculated at the Homogeneous Material level.
  • Example: If a supplier provides a copper wire with a plastic PVC jacket, the 0.1% threshold for restricted phthalates applies only to the weight of the plastic jacket, not the weight of the entire wire.
• REACH SVHC Threshold: Calculated at the Article level. (The O5A ruling - "Once an Article, Always an Article").
  • Example: If an SVHC is present in the plastic jacket, you calculate the concentration of that SVHC against the total weight of the plastic jacket (which is the "article" in this context before it was assembled into a complex machine). If it exceeds 0.1% w/w (weight by weight), it triggers reporting obligations.

What Exactly Should You Ask Your Suppliers For?¶

Stop asking for a "REACH/RoHS Certificate." You must separate your requests to ensure legal validity.

For RoHS (if you make electronics): Ask for a Certificate of Compliance (CoC) that explicitly references Directive 2011/65/EU (and amendment 2015/863). The certificate must state that none of the 10 restricted substances are present above the homogeneous material thresholds, OR it must explicitly list the Annex III/IV exemptions the component relies on.

For REACH SVHCs (all manufacturers): Ask for an SVHC Declaration referencing the most recent ECHA Candidate List. Because the list updates every six months, a REACH certificate from 2024 is entirely useless in 2026. The supplier must declare whether any of the currently listed 240+ SVHCs are present in the component above 0.1% w/w. If yes, they must provide the exact name, CAS number, and concentration of the substance.

Simplifying Supplier Communication with Sustalium¶

Managing bi-annual REACH updates and complex RoHS homogeneous material calculations via email is impossible at scale.

Sustalium provides a specialized REACH & RoHS compliance platform that does the heavy lifting for you. We provide structured, regulation-specific data input forms for your suppliers.

When ECHA updates the REACH Candidate List in January or July, Sustalium automatically cross-references the new substances against your existing BOM data, instantly flagging which suppliers you need to re-survey. This ensures your compliance documentation is always perfectly aligned with the law.

Frequently Asked Questions¶

If my product is RoHS compliant, is it automatically REACH compliant? No. While there is some overlap (e.g., Lead is restricted under RoHS and is also an SVHC under REACH), REACH covers hundreds of additional chemicals that RoHS does not. You must evaluate and document compliance for both separately.

What is the SCIP Database? Under the EU Waste Framework Directive, if your product contains a REACH SVHC above 0.1% w/w, you are legally required to submit a dossier detailing that substance to ECHA's SCIP (Substances of Concern In articles as such or in complex objects (Products)) database before placing the product on the market.

Last updated: June 7, 2026