RoHS and REACH Compliance FAQ: How to Assess Product Compliance

RoHS and REACH compliance are two of the environmental requirements most frequently encountered by electronics manufacturers, but they regulate products in different ways.

RoHS primarily restricts specified hazardous substances in electrical and electronic equipment, generally at the homogeneous-material level. REACH is much broader: it regulates chemicals across the European Union and can create obligations relating to substances, mixtures and articles, including requirements concerning Substances of Very High Concern (SVHCs) and restrictions under Annex XVII. EU RoHS currently restricts ten substances under Directive 2011/65/EU, as amended.

For manufacturers of complex electronic products, complying with both regulations often requires more than obtaining generic supplier certificates. Companies may need to understand the complete product structure, collect documentation for individual parts and materials, verify exemptions, identify data gaps and use targeted laboratory testing where documentary evidence is insufficient.

This FAQ explains the practical differences between RoHS and REACH, which parts of a product should be assessed, what supplier evidence is typically needed and how a combined product compliance assessment can be performed.

Related guidance:

RoHS vs. REACH: What Is the Difference?

Topic	RoHS	REACH
Main purpose	Restricts specified hazardous substances in electrical and electronic equipment	Broad chemical regulation addressing substances, mixtures and articles
Typical product scope	Electrical and electronic equipment	Very broad range of chemicals and products
Key assessment level	Homogeneous material	Depends on the obligation; Candidate List communication is assessed at article level
Common compliance questions	Are restricted substances below applicable limits? Does an exemption apply?	Are SVHC, Article 33, SCIP, Annex XVII or other obligations applicable?
Typical evidence	Supplier declarations, technical documentation, material data, analytical testing	Supplier declarations, SVHC information, material disclosures, restriction review and analytical evidence
Ongoing maintenance	Reassess when materials, suppliers, exemptions or legislation change	Reassess when suppliers, materials, Candidate List entries or restrictions change

Both regulations therefore depend heavily on reliable product and supplier data, but they require different regulatory analyses.

RoHS and REACH FAQ

Which Parts of a Product Need to Be Assessed for RoHS and REACH?

For a complex electronic product, the assessment should generally begin with the complete product structure, not simply the finished assembly.

Relevant parts and materials can include printed circuit boards, solder, connectors, cables and cable insulation, plastic housings, metal alloys, surface finishes, coatings, adhesives, inks, labels, screws, hardware, rubber components and accessories.

For RoHS, restricted-substance concentration limits are generally evaluated at the homogeneous-material level. A component such as a cable may therefore contain several homogeneous materials that need to be considered separately.

REACH can require a different analysis because Candidate List obligations apply to articles. For complex products composed of multiple articles, the relevant SVHC threshold is not simply calculated against the total finished-product weight.

Batteries and packaging should also be identified within the overall product data, even though separate regulatory frameworks may apply to them.

When Is a Product RoHS Compliant?

For EU RoHS, manufacturers need evidence that the restricted substances do not exceed the applicable maximum concentration values in homogeneous materials, unless a valid exemption applies.

Restricted substance	Maximum concentration
Lead	0.1%
Mercury	0.1%
Hexavalent chromium	0.1%
PBB	0.1%
PBDE	0.1%
DEHP	0.1%
BBP	0.1%
DBP	0.1%
DIBP	0.1%
Cadmium	0.01%

Compliance does not necessarily mean that a restricted substance is completely absent. A material may contain a substance below the applicable limit, or a particular application may qualify for an exemption.

Consequently, a result such as “lead detected” does not by itself demonstrate RoHS non-compliance.

What Is a Homogeneous Material Under RoHS?

A homogeneous material is generally a material of uniform composition that cannot be mechanically separated into different materials.

A connector, for example, may contain several homogeneous materials:

metal contacts;
plating;
plastic housing;
solder; and
coatings.

RoHS concentrations are therefore not simply averaged across the complete connector or finished product.

This distinction is particularly important for substances such as lead and cadmium because averaging concentrations across an entire assembly could hide a high concentration within one small material.

How Do RoHS Exemptions Work?

RoHS exemptions permit certain restricted substances above the normal concentration limits in defined technical applications.

An exemption should not simply be copied from an old supplier declaration. The assessment should verify:

whether the exemption applies to the exact material or application;
whether it applies to the relevant product category;
whether it remains valid;
whether applicable technical conditions are satisfied; and
whether its use is properly documented.

Exemptions can be renewed, amended, replaced or expire, so they require ongoing review.

What About “RoHS 2” and “RoHS 3”?

EU RoHS is based on Directive 2011/65/EU, as amended.

The term “RoHS 3” is commonly used in industry to refer to Directive (EU) 2015/863, which added DEHP, BBP, DBP and DIBP to Annex II. It is not a separate replacement RoHS directive.

See our RoHS 2 vs. RoHS 3 Guide

What Is REACH and How Does It Apply to Products?

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals.

Although REACH is often discussed in relation to chemicals, it also creates important obligations for manufacturers, importers and suppliers of articles.

For electronics companies, a product assessment may need to consider:

Candidate List SVHC obligations;
Article 33 supply-chain communication;
SCIP notification requirements where applicable;
Annex XVII restrictions; and
other obligations depending on the substance and the company’s role.

For this reason, a generic statement saying simply “REACH compliant” may not provide sufficient information to establish that all relevant obligations have been addressed.

What Are REACH SVHCs?

SVHC means Substance of Very High Concern.

Substances meeting specified hazard criteria can be added to the REACH Candidate List. Because the Candidate List changes over time, supplier declarations and technical files may need to be updated when new entries are added.

If a Candidate List substance is present in an article above 0.1% w/w, specific communication and potentially other obligations can apply.

The date and substance scope of a supplier declaration therefore matter. A declaration prepared several years ago may no longer cover the current Candidate List even if the product itself has not changed.

When Must SVHC Information Be Communicated?

Under REACH Article 33, suppliers of articles containing Candidate List SVHCs above the applicable threshold may have supply-chain communication obligations.

For complex products, manufacturers should therefore know which article contains the SVHC, rather than simply asking whether the substance represents more than 0.1% of the total finished-product weight.

A useful supplier declaration should identify, where applicable:

the article or part number;
the Candidate List version or assessment date;
any SVHC above the relevant threshold;
the substance name;
concentration or concentration range where available;
information necessary for safe use; and
the responsible supplier or manufacturer.

A statement saying only “REACH compliant” may therefore be insufficient for a detailed assessment.

What Documentation Is Needed for a RoHS and REACH Assessment?

The starting point is normally a reliable Bill of Materials (BOM).

Where possible, the BOM should identify:

internal part number;
manufacturer;
manufacturer part number;
component description;
alternative sources;
known materials or finishes; and
supplier information.

Supporting evidence may include:

RoHS declarations;
REACH declarations;
Full Material Disclosures;
Certificates of Compliance;
analytical test reports;
safety data sheets where relevant;
exemption declarations;
technical documentation; and
material composition information.

The important question is not simply whether a document exists.

The evidence must demonstrably apply to the component or material being assessed.

A declaration may be inadequate if it does not identify the exact part number, references an outdated Candidate List, addresses an incomplete RoHS substance scope, fails to identify an exemption, covers another material formulation or cannot be traced to the manufacturer.

Learn more about Full Material Disclosures

Enviropass 2026 Project Data

RoHS and REACH remain among the most frequently assessed requirements in our project portfolio.

RoHS appeared in 32.5% of the Enviropass projects analyzed between January and August 2026, while REACH appeared in 26.7%.

Among the REACH projects reviewed, approximately 30% required additional supplier follow-up because the available declaration was incomplete, outdated or insufficiently specific.

These findings reinforce an important practical lesson: RoHS and REACH compliance depend heavily on the quality and applicability of product and supplier evidence—not simply on collecting certificates.

See the full 2026 Product Environmental Compliance analysis

Source: Enviropass Expertise Inc., 2026 Product Compliance Project Portfolio, January–August 2026.

How Does Enviropass Perform a RoHS and REACH Product Assessment?

A combined RoHS and REACH assessment can generally be organized into the following stages.

1. Review the Product BOM

The first step is to understand the product structure and identify components, manufacturers, manufacturer part numbers, materials and alternative sources.

Missing materials such as solder, coatings, adhesives or alternative components can create significant evidence gaps.

2. Collect Existing Supplier Evidence

Available documentation is collected from the client, manufacturers and suppliers.

This may include RoHS and REACH declarations, Full Material Disclosures, technical datasheets, exemption information and analytical reports.

3. Verify Document Applicability

Each document is reviewed to determine whether it covers:

the correct manufacturer;
the correct part number;
the applicable regulatory scope;
the appropriate substances or Candidate List;
the relevant date; and
any exemptions or limitations.

4. Assess RoHS Compliance

Available evidence is reviewed against applicable RoHS restricted substances and concentration limits.

Potential exemptions are identified and reviewed for applicability and validity.

5. Assess REACH Requirements

Supplier information is reviewed for Candidate List SVHCs and other applicable REACH obligations.

Depending on scope, this may include Article 33, SCIP and Annex XVII considerations.

6. Identify Evidence Gaps

Components with incomplete, outdated or ambiguous evidence are identified.

Additional actions may include supplier follow-up, updated declarations, Full Material Disclosures, technical clarification or laboratory testing.

7. Use Targeted Testing Where Necessary

Analytical testing can be useful when documentation is missing, inconsistent or technically insufficient.

Testing should be risk-based and targeted, rather than automatically testing every component for every possible substance.

Learn more about Chemical and Product Compliance Testing

8. Document the Compliance Conclusion

The final assessment should maintain a traceable record of:

evidence reviewed;
regulatory scope;
exemptions;
identified substances;
unresolved gaps;
analytical results; and
conclusions.

This creates a compliance file that can be maintained as suppliers, products and regulations change.

Additional Practical Questions

Can Laboratory Testing Replace Supplier Documentation?

Usually not entirely.

Laboratory testing and documentary assessment answer different questions.

A laboratory test can establish whether specified analytes were detected in a particular sample at defined detection limits. It does not automatically establish whether every production batch is identical, whether an untested substance is absent, whether an exemption applies, whether every material was tested or whether supply-chain communication obligations have been addressed.

Likewise, supplier documentation alone may be inadequate when it is outdated, generic or not demonstrably applicable to the component.

For complex electronic products, the strongest approach often combines documentary review, supplier investigation, risk assessment and targeted analytical testing.

Are RoHS and REACH One-Time Compliance Exercises?

No.

A product that was adequately documented when launched can require reassessment when:

a supplier changes;
an alternative component is introduced;
a material formulation changes;
a new Candidate List SVHC is added;
a REACH restriction changes;
a RoHS exemption changes or expires; or
the product enters a new market.

Product environmental compliance should therefore be integrated into change management and supplier-data management, rather than treated only as a pre-market certification exercise.

RoHS and REACH Compliance: Key Takeaways

For electronics manufacturers:

RoHS and REACH are separate regulatory frameworks and should not be treated as interchangeable.
RoHS generally evaluates restricted substances at the homogeneous-material level.
REACH can create Candidate List, Article 33, SCIP, Annex XVII and other obligations.
A complete BOM is one of the most important inputs to a reliable product assessment.
Generic supplier statements may not provide sufficient evidence.
RoHS exemptions need to be checked for applicability and validity.
REACH declarations need to be sufficiently current.
Laboratory testing is most useful when directed toward identified evidence gaps.
Compliance needs to be reassessed when products, suppliers or regulations change.

For detailed regulatory guidance:

RoHS Compliance Worldwide
Current REACH SVHC Compliance Guide

Need a RoHS and REACH Product Assessment?

Enviropass can review your product structure, BOM, supplier documentation and available analytical evidence to identify compliance gaps and determine whether additional supplier follow-up or targeted testing is appropriate.

The objective is not simply to collect more certificates. It is to determine whether the available evidence actually supports the product’s RoHS and REACH compliance conclusions.

Request a Product Compliance Assessment

Technical Review

Written and technically reviewed by: Aurélien “Aury” Hathout, M.Env., VEA®, CEA

Last technical review: September 2026

This page was reviewed for technical accuracy based on the EU RoHS Directive, the REACH Regulation, applicable European Commission and ECHA guidance, and recognized technical documentation practices for product compliance assessments.

Regulatory Sources

This guide is based on primary and authoritative European Union regulatory and technical sources, including:

Directive 2011/65/EU — EU RoHS Directive — restrictions on certain hazardous substances in electrical and electronic equipment.
Commission Delegated Directive (EU) 2015/863 — addition of four phthalates to the RoHS restricted-substance list.
Regulation (EC) No 1907/2006 — REACH Regulation — EU framework governing chemical substances, including Candidate List communication obligations and restrictions.
ECHA Candidate List of Substances of Very High Concern (SVHCs) — current Candidate List used when evaluating applicable REACH Article 33 communication requirements.
IEC 63000 — Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances — framework commonly used to organize RoHS technical evidence.