RoHS vs REACH: how the two regulations differ

RoHS and REACH are two EU chemical-compliance regimes that manufacturers routinely confuse, partly because both restrict hazardous substances in products and both feed into market access in Europe. But they differ in scope, in the substances they cover, and in the obligations they create. Understanding the difference tells you which declarations you owe, and to whom.

Scope: electronics vs (almost) everything

RoHS, Directive 2011/65/EU, applies to electrical and electronic equipment (EEE), and restricts a fixed list of ten substances in homogeneous materials. REACH, Regulation (EC) 1907/2006, is far broader: it governs chemical substances on their own, in mixtures, and in articles across essentially all product categories, and its Candidate List of Substances of Very High Concern grows over time.

Where they overlap

The two overlap more than their scopes suggest. An electronic product is almost always in scope for both: RoHS restricts its ten substances in the equipment, while REACH SVHC duties still apply to any Candidate List substance present above 0.1% in its articles. A phthalate like DEHP is restricted under RoHS 3 and is also a REACH SVHC, so the same substance can appear in both assessments. In practice, a manufacturer of electronics typically issues a RoHS declaration and, separately, manages REACH SVHC communication.

Managing both without duplicated effort

Because both regimes rest on the same underlying data (the composition of your product down the bill of materials), the efficient approach is to capture that data once and generate each declaration from it. Holding substance data and declaration templates in a controlled structure keeps a RoHS declaration and a REACH/SVHC statement consistent with each other and current as lists change. DataSheets Pro provides structured starting points for these declarations; determining scope, thresholds and which obligations apply to your products remains your responsibility.