RoHS vs. REACH

Imagine this perfect evening. A room smelling of fresh linens, dimmed lights, and clouds drifting lazily across the ceiling. A child lies gazing upward, clearly fascinated, while you stand in the doorway feeling a profound sense of relief. You bought this projector for one specific reason: to create the safest place in the world for them, where they could easily wind down.

This idyll lasts only until regulatory authorities publish a single, brief report. A standard, dry bulletin that shatters this sense of security into a million pieces. In 2025, the EU market surveillance system (case no. SR/03886/25) ordered the immediate recall of this specific projector from all retail outlets. The reason? At the core of this beautiful toy, right on the integrated circuits, inspectors found solder composed of 82% lead. This gadget is a textbook wolf in sheep's clothing, while it lulled the child to sleep on the outside, it concealed heavy, toxic chemicals on the inside, posing a direct threat to their developing nervous system.

As an entrepreneur, importer, or manufacturer placing equipment on the market, you shoulder a tremendous responsibility. Every customer who chooses your product extends a line of trust to your brand, believing that you are delivering a completely safe solution for their loved ones. In today's complex supply chains, rigorous verification and conscious quality management are the keys to success. Building a business based on tested, certified products is not merely a shield against severe financial penalties or the risk of government-mandated recalls; above all, it is the bedrock of a lasting brand image and a demonstration of genuine care for consumer health.

As a business owner, you don't have to flawlessly navigate the intricacies of EU law on your own. However, to effectively fulfill this mission and safeguard your business, it is crucial to understand the fundamental rules and establish a secure course of action. Let us examine the practical differences between the RoHS Directive and the REACH Regulation, and explore why both of these frameworks serve as the absolute pillars of safety in the electronics industry.

What is RoHS, and what is REACH?

Many entrepreneurs taking their first steps in the import business treat the RoHS and REACH acronyms interchangeably. There also often lingers a highly dangerous misconception: "Since my supplier provided a RoHS certificate, REACH no longer applies to me."

This is a critical error. To safely place products on the market, you must understand that these two regulations are not mutually exclusive, they are complementary.

The RoHS Directive (Restriction of Hazardous Substances)

Simply put, this is a regulation designed exclusively for the electrical and electronic equipment (EEE) industry. Its primary objective is to restrict the volume of hazardous substances leaching into the environment from the ever-growing mountain of e-waste, as well as to protect individuals who come into contact with these products.

• It applies strictly to equipment dependent on electric currents or electromagnetic fields to function properly.

• RoHS is highly precise. It prohibits exceeding strictly defined limits for 10 specific substances within so-called homogeneous materials, for instance, within the plastic of the casing itself, rather than calculated across the entire device as a whole.

• The RoHS blacklist includes heavy metals such as lead, mercury, cadmium, and hexavalent chromium; flame retardants like PBBs and PBDEs; and 4 types of phthalates, toxic plastic softeners notoriously detected in cheap cable insulation.

The REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals)

If RoHS is a precision sniper targeting electronics, REACH is a massive EU net cast over nearly all physical products sold in Europe, from clothing and toys, to furniture and cosmetics, right up to household appliances and consumer electronics.

• It governs the registration, evaluation, authorisation, and restriction of chemicals. It applies to every single chemical substance contained within your product.

• The beating heart of REACH is the constantly updated SVHC (Substances of Very High Concern) list. This is a "living" document updated by the European Chemicals Agency (ECHA). Currently, it features well over 200 entries (and that number keeps growing!).

• If the concentration of any substance from the SVHC list in any component of your product (e.g., in a rubber gasket) exceeds the threshold of 0.1% by weight, it imposes strict informational obligations on you towards consumers and the mandatory requirement to register the product in the EU's SCIP database.

Both RoHS and REACH verify the chemical composition of the materials used to manufacture the equipment. Testing laboratories are not concerned with whether a device looks visually appealing; they investigate what is hidden inside. They analyze what the plastic casing is molded from, what type of solder was applied to the PCB, and what plasticizers were used to soften the power cord's insulation.

What does this protect the end user from?

First and foremost, against silent, long-term exposure to carcinogenic, mutagenic, and endocrine-disrupting substances. It eliminates scenarios where toxic phthalates leach from a cable held by a child, or where carcinogenic cadmium and lead seep from cheap integrated circuits into the air of a home, or, once the equipment is discarded in a landfill, into the groundwater.

Who bears legal responsibility, and for which products are RoHS and REACH an absolute requirement?

Under EU law, the responsibility for chemical safety and compliance with the RoHS Directive and the REACH Regulation rests with the entity that first places the product on the European Union market. This means these regulations are critical for:

• Direct importers (e.g., those sourcing finished equipment from Asian markets).

• Manufacturers producing or assembling equipment within the EU territory.

• Distributors and companies operating under the OEM model, who purchase finished products from foreign factories but brand and sell them under their own logo (in the eyes of the law, you assume the obligations of a manufacturer in this scenario!).

• Authorized representatives of foreign brands in Europe.

The principle is brutally simple. If irregularities are detected, as was the case in the story with our projector, Polish or EU market surveillance authorities are not going to chase down a factory in Shenzhen. They will always knock on the door of the EU-based entity, which means you.

Which products are strictly subject to RoHS, and which to REACH?

RoHS: A mandatory requirement for electronics and the CE mark!

The RoHS Directive is strictly required for any device powered by an electric current or electromagnetic fields. The scale doesn't matter; it applies equally to small consumer electronics (smartwatches, wireless headphones, USB cables), electronic toys, and LED lighting, all the way up to large household appliances and industrial machinery. If a product has a plug or a battery, it falls under RoHS.

Compliance with the RoHS Directive is a legal prerequisite for lawfully affixing the CE mark to electronic equipment! If you issue a CE Declaration of Conformity (DoC) without rigorous verification of RoHS requirements, your document is legally invalid, and the CE mark has been affixed illegally.

REACH: A mandatory requirement for every physical product.

As you already know, REACH is a much broader surveillance net. It is an absolute "must-have" for every physical item placed on the market. Imagine that, in addition to electronics, you import ordinary plastic smartphone cases. No electric current flows through them, so they do not fall under RoHS and do not require a CE mark. However, they are still strictly subject to the REACH Regulation! You must be certain that the rubber or plastic used in their production does not release phthalates and does not contain SVHC substances above the 0.1% threshold.

If you import or manufacture electronics, you find yourself at the crossroads of these two major legislative acts. Your product must pass through both filters, as electronics is a segment where RoHS and REACH form an inseparable package.

When does your responsibility begin, and what exemptions does the law allow?

Both RoHS and REACH regulations become fully binding the moment a product is placed on the European Union market. In practice, this translates to one of two scenarios:

1. Physical border crossing: The moment of customs clearance and the release of goods for free circulation by the Customs Office.

2. Offering for sale: The moment the product is listed for sale, such as on an e-commerce platform or an online store within the EU territory.

From that very second, you must possess comprehensive documentation and test reports validating the safety of your equipment. Customs authorities or the Trade Inspectorate can demand these documents at any given moment.

Exemptions in the RoHS Directive – what do you need to know?

The RoHS Directive completely exempts equipment intended for highly specific purposes from its strict requirements. This includes, among others, military equipment, devices designed to be sent into space, and large-scale stationary industrial tools and machinery. For standard consumer electronics, the regulations are unforgiving; however, there is a certain caveat.

Time-limited exemptions: The RoHS Directive allows for specific exemptions, detailed in dedicated annexes, such as Annex III. This means that in strictly defined technical applications, for example, in certain brass or aluminum alloys, a higher concentration of lead is permitted than the standard 0.1%. These exemptions, however, come with an expiration date. The European Union regularly reviews and phases them out. What was perfectly legal two years ago could be the very grounds for a market recall of your goods today. For this reason, a one-time test is simply not enough! Periodic auditing of your compliance documentation is an absolute necessity in the electronics industry.

Exemptions in the REACH Regulation

In the case of REACH, materials completely exempt from verification include, among others, waste, radioactive substances, and products subject to separate, overarching, and even more stringent regulations, such as pharmaceuticals, food, and cosmetics.

For electronics, which are classified under REACH as "articles," the key concept is the 0.1% weight by weight (w/w) threshold for substances on the SVHC list. Unlike RoHS, detecting an SVHC substance above 0.1% in a product's casing does not always trigger an immediate ban on its sale. It does, however, force you down a highly demanding bureaucratic path. It imposes an absolute obligation on you to disclose this information to all participants in the supply chain and, upon request, to any consumer. Furthermore, it places a legal requirement on you to register the product, complete with a detailed chemical description, in the EU's SCIP database, which is managed by the European Chemicals Agency (ECHA).

How to build documentation that shields you from the risk of penalties?

In the eyes of customs officials and market surveillance inspectors, your product is worth exactly as much as the documentation backing it up. How, then, do you build an ironclad compliance file for electronic equipment?

The BOM (Bill of Materials): The roadmap of your product

Everything begins with the BOM, a comprehensive, itemized list of materials. Before you can even begin verifying certificates, you need to know exactly how many and what specific components make up your device. Every single integrated circuit, capacitor, piece of the plastic casing, rubber gasket, screw, and even the dye used in your logo represents a distinct homogeneous material that must be rigorously accounted for in your risk assessment.

Documentation for the RoHS Directive

To legally issue a CE Declaration of Conformity (DoC) for your equipment, your technical documentation must meet stringent requirements, such as the EN IEC 63000 standard, and be grounded in hard data:

• Component reports and declarations: You must compile a complete set of test reports for every single component listed in your BOM from your subcontractors.

• Analytical verification: This is where a professional laboratory comes into play. The most popular and fastest method for screening components for heavy metals is non-destructive X-ray fluorescence (XRF) spectrometry. If the initial scan yields an inconclusive result, the material is subjected to advanced chemical analysis, such as ICP-OES or GC-MS methods, which flawlessly detect toxic phthalates in cable insulation.

Documentation for the REACH Regulation

The primary objective here is to prove that you are actively monitoring the continuously updated SVHC list:

• REACH SVHC Declarations: Collecting written statements from your suppliers confirming that the supplied components do not contain substances from the latest ECHA Candidate List in concentrations exceeding 0.1%.

• Data management: Should laboratory testing reveal the presence of SVHC substances above this threshold, your documentation must be expanded to include appropriate safe-use instructions for consumers, along with proof of the product's registration in the EU's SCIP database.

Compliance as your greatest competitive advantage

Placing a safe product on the market, backed by irrefutable, legal documentation supported by rigorous laboratory testing, is currently the most effective way to outpace the competition. In an era of highly saturated markets, a strong position is built on the foundation of uncompromising integrity.

Consumer trust is the hardest currency on the market. Possessing an ironclad compliance file proves that your company does not cut corners when the health and safety of end-users are at stake. Treating certification as a strategic investment, rather than a mere bureaucratic hurdle, is a conscious strategy for building a long-term business advantage and establishing your brand as an expert in the industry.

Verifying certificates and standards requires specialized knowledge, but you do not have to navigate this process alone. At DLP-Poland, we support entrepreneurs by managing the entire compliance journey from A to Z. We assist in diligently compiling the required documentation, professionally verifying the certificates provided by factories, and, should the need arise, conducting the necessary tests in our own laboratory.

Take the risk off your shoulders. Gain peace of mind and the absolute certainty that your product is 100% legal, completely safe, and fully ready for European markets.