RoHS vs REACH for Electronics: Key Differences

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RoHS limits ten substances, such as lead and cadmium, in each homogeneous material of electrical and electronic equipment sold in the EU, backed by a declaration of conformity and CE marking. REACH is the general EU chemicals law. For a device, it mainly means tracking Candidate List substances above 0.1% by weight and passing that information on.

Supplier forms often list RoHS and REACH side by side. They are two separate EU laws with different lists, different math and different paperwork. A connected device sold in the EU usually has to deal with both. This guide explains what each law asks of a device maker, where they overlap, and which documents to collect from suppliers before your first EU shipment.

This is an engineering summary and does not replace legal advice. Rules and lists change, so check the current text before you rely on any value here. The ECHA site could not be read for this article, so the REACH points are taken from Commission, EU Ombudsman, Irish authority and chip vendor pages, each linked and read in November 2026.

RoHS vs REACH: what is the difference for an electronic device?

The Commission's RoHS FAQ puts it in one line: RoHS is a sector-specific directive on hazardous substances in electrical and electronic equipment (EEE), while REACH is a general act on the registration, evaluation, authorization and restriction of chemical substances (as of November 2026). RoHS asks whether ten substances stay under fixed limits. REACH asks which substances of concern are in your product, and whether you told the people you sell to.

Sources, as of November 2026: European Commission RoHS page, RoHS 2 FAQ (December 12, 2012), European Commission REACH page, TI environmental FAQ, Ireland HSA and EU Ombudsman case 1944/2020/TE.

What is RoHS, and what does RoHS compliance require?

RoHS is Directive 2011/65/EU, often called RoHS 2. The Commission says it covers all products with an electrical and electronic component, unless specifically excluded (as of November 2026). A wearable, a tracker or a voice device is in scope unless an exclusion applies.

The ten restricted substances

The Commission lists lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates: DEHP, BBP, DBP and DIBP (as of November 2026). Commission Delegated Directive (EU) 2015/863 added the four phthalates, and Member States apply it from 22 July 2019 (EUR-Lex, as of November 2026).

Annex II, as replaced by that directive, sets the maximum concentration by weight in homogeneous materials at 0.1% for each substance, except cadmium at 0.01%. TI's FAQ shows the same first six values in ppm: 1,000 ppm, and 100 ppm for cadmium (both as of November 2026). For medical devices and monitoring and control instruments, the same directive applies the phthalate restriction from 22 July 2021.

Why homogeneous material matters

The FAQ defines a homogeneous material as one with a uniform composition, or a combination that cannot be separated by mechanical actions such as unscrewing, cutting, crushing or grinding. Its examples are a plastic cover, the copper wire inside a cable, and the solder in a joint. Each limit applies to each homogeneous material on its own (RoHS 2 FAQ, Q9.8, as of November 2026).

So you cannot average a lead-bearing solder joint across the weight of the whole board. TI says its ppm figures are worst-case values at the homogeneous material level.

Declaration, technical file and CE marking

The FAQ says the manufacturer, or its authorized representative established in the EU, draws up an EU declaration of conformity, and the manufacturer draws up the technical documentation. All EEE in scope must be CE marked, and EEE in scope that bears CE marking is presumed to meet the RoHS limits. Where several EU acts require a declaration, the FAQ encourages a single declaration covering all of them (Q8.2 to Q8.4 and Q8.11, as of November 2026). For how the declaration and CE marking work for a radio device, see FCC vs CE certification.

The 2012 FAQ names EN 50581:2012 for the technical documentation. Following the standard does not stop enforcement: Member States may still analyze the product, and the manufacturer bears full responsibility for any violation (Q9.6, as of November 2026). The IEC lists IEC 63000:2016+AMD1:2022, edition 1.1, published January 14, 2022, which specifies the technical documentation the manufacturer compiles to show it meets the substance restrictions (IEC webstore, as of November 2026). Both standards are paid, and we quote nothing from inside them.

What does REACH compliance require for a finished device?

REACH is Regulation (EC) No 1907/2006. The Commission says chemical substances that exceed 1 tonne per year per company must be registered with ECHA (as of November 2026). Your Europe places registration on companies that manufacture or import a substance in the EEA (Your Europe, last checked June 23, 2026, read November 2026). For a device maker, the main duties concern the substances inside the product, which REACH calls an article.

Candidate List substances above 0.1%

SVHCs go on the Candidate List. TI's FAQ says the list is usually updated twice a year, and that an SVHC above the 0.1% article threshold is not restricted from use. Further information must be available when one is present (as of November 2026).

The EU Ombudsman describes the REACH Article 33(1) duty as giving sufficient information, available to the supplier, to allow safe use of the article. The Commission adds that consumers can ask whether a product contains an SVHC, and companies must reply within 45 days (both as of November 2026).

Notifying ECHA

Ireland's Health and Safety Authority (HSA) says producers and importers of articles must notify ECHA when a Candidate List substance is present in their articles above 0.1% w/w and in a quantity of over one tonne per year. The duty applies no later than six months after the substance joins the list. It does not apply when exposure can be excluded during normal and reasonably foreseeable conditions of use, including disposal, or when the substance is already registered for that use (as of November 2026). Run the tonnage math for each SVHC once your volumes are known.

The SCIP database

SCIP has its legal basis in Article 9(1)(i) of the EU Waste Framework Directive. The EU Ombudsman says a 2018 amendment to that directive requires suppliers of articles to provide information on substances of concern to ECHA as from January 5, 2021, and that the duty concerns information pursuant to REACH Article 33(1), the Candidate List duty above. ECHA makes this data accessible to waste treatment operators, and to consumers on request (EU Ombudsman case 1944/2020/TE, as of November 2026).

Annex XVII restrictions

REACH also restricts some substances outright through Annex XVII. TI marks a part as not compliant with REACH when it contains an Annex XVII substance outside its allowed application, and says that list is updated as needed (as of November 2026). This is the part of REACH that works most like RoHS, with restrictions tied to specific uses.

Where do RoHS and REACH overlap?

The Commission's FAQ says RoHS does not affect the application of REACH, and REACH does not affect RoHS, for substances in EEE. When the two overlap, the strongest restriction applies, meaning the lowest maximum concentration (Q1.5, as of November 2026).

In practice this gives a device team three rules.

• A RoHS certificate says nothing about the Candidate List. Collect both statements for every part.
• A RoHS exemption only works within RoHS. A part that uses one still has to be checked for SVHC content under REACH.
• The REACH check is a moving target. A part with no listed SVHC last year can become affected after a Candidate List update, with no change to the part.

What RoHS and REACH data should you collect from suppliers?

The FAQ says the finished EEE can only meet RoHS if all its components and parts do, including non-electronic parts like fasteners and the plastic case. Components used in finished EEE must meet the limits but do not need CE marking (Q7.3, as of November 2026). So the data has to cover the whole BOM, down to the screws.

Some chip vendors publish this data per part. TI's material content search gives a specific product's RoHS, REACH and Green compliance status, with material content or restricted chemical test reports, and its download links TI's signed EU RoHS Material Declaration Certificate (TI environmental information, as of November 2026). The IPC lists IPC-1752C (June 2026) as the current version of its materials declaration standard, and says the structure of IPC-1752B mirrors the ECHA SCIP submission format (IPC materials declaration page, as of November 2026).

Custom parts are where the gaps appear. A molded housing, a printed label, a foam gasket or a cable assembly made for your device has no catalog page. Ask each of those suppliers for a declaration that names your part number and the resin or material grade, and keep it with the BOM row. The bill of materials guide shows where compliance data sits on each line.

Alternates are the other gap. When a buyer swaps in a second-source capacitor or a different screw, the declaration on file no longer matches. Make a declaration check part of every engineering change order.

Which duties land on a US company selling into the EU?

The duties above are written for manufacturers, importers and suppliers placing products on the EU market. The FAQ says the manufacturer, or its authorized representative established in the EU, draws up the declaration of conformity (Q8.2, as of November 2026). HSA places the ECHA notification on producers and importers of articles. The Ombudsman decision places the SCIP duty on suppliers of articles.

If you ship to an EU distributor, agree in writing who acts as importer, who holds the technical file, who submits SCIP data, and who answers consumer requests. Whoever takes those roles will ask you for the supplier data in the table above, so collect it during development, before the first production order.

Two scope notes from the 2012 FAQ. Packaging is outside RoHS 2 because it falls under the packaging directive. Batteries and accumulators were outside RoHS because they had their own directive at the time (Q6.8 and Q1.6, as of November 2026). Battery rules have changed since 2012, so check the current battery law separately. For R&D prototypes, see the FAQ below.

What should you ask your hardware team?

Bring this list to the BOM review before you order production parts, and write down who owns each answer.

• Does every BOM line have a RoHS declaration on file, including screws, foam, adhesives, labels, cables and the enclosure resin?
• Which parts rely on a RoHS exemption, which exemption is it, and when does it expire?
• Has every supplier stated its Candidate List content above 0.1%, and against which list update?
• Which custom parts (molded housings, printed labels, cable assemblies) have no catalog declaration, and who will request or test them?
• Who is the EU importer, and who answers customer and consumer requests under REACH?
• When an alternate part replaces a BOM line, does the change order require a new declaration?
• Where is the technical file kept, and who updates it when the Candidate List changes?

Part choices are easiest to change early. For how a project starts and what the first paid study looks at, see what Gate 0 Feasibility covers.

If you are planning a device for the US and the EU, tell us about your device.

Sources. All pages accessed November 6, 2026. Lists and exemptions change, so confirm current values before you decide.

• European Commission, RoHS Directive (link)
• European Commission, DG Environment, RoHS 2 FAQ (December 12, 2012; the FAQ says it is not legally binding) (link)
• EUR-Lex, Commission Delegated Directive (EU) 2015/863 (link)
• European Commission, REACH Regulation (link)
• Your Europe, Registering chemicals (REACH), last checked June 23, 2026 (link)
• Health and Safety Authority (Ireland), Notification of substances in articles (link)
• European Ombudsman, decision in case 1944/2020/TE (December 3, 2020) (link)
• Texas Instruments, Environmental information FAQs (link)
• Texas Instruments, Environmental information (link)
• IPC, Materials declaration data exchange standards (link)
• IEC, IEC 63000:2016+AMD1:2022 CSV (link)