REACH vs RoHS: what's the difference, and do you need both?

REACH and RoHS get mentioned in the same breath so often that a lot of manufacturers assume ticking one box covers the other. It doesn't. RoHS bans ten specific substances above a fixed weight limit in electrical and electronic equipment; REACH's Substance of Very High Concern (SVHC) duty is a disclosure obligation tied to a list of over 250 chemicals that gets longer roughly twice a year. One is a hard ban with a threshold you either pass or fail. The other is a moving target you have to keep checking against, for as long as you sell the product.

If you make or import electronics for the EU, you're almost certainly in scope for both — but they ask different things of you, on different timescales, and mixing them up is one of the more common gaps we see in technical files that otherwise look complete.

What RoHS actually restricts

RoHS — the Restriction of Hazardous Substances Directive, 2011/65/EU — bans ten substances above a set concentration in the electrical and electronic equipment it covers: lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates (DEHP, BBP, DBP and DIBP) added in a later update. The limit is 0.1% by weight for every substance except cadmium, which is capped at a much stricter 0.01%.

Crucially, that limit doesn't apply to the finished product, and it doesn't apply component-by-component either. It applies to every homogeneous material — meaning any material that can't be mechanically separated into something else by unscrewing, cutting, crushing or abrasion. A single connector might contain a plastic housing, a metal pin and a solder joint, and RoHS treats each of those as its own homogeneous material with its own 0.1% (or 0.01%) ceiling. Fail the threshold in any one of them and the whole product falls outside the directive's requirements, however clean the other 99% of the bill of materials is.

RoHS compliance is, in that sense, binary. You test, you either pass every homogeneous material against every restricted substance or you don't, and the list of what you're testing against hasn't changed since the phthalate additions took effect. It's a known, closed set.

What REACH actually requires

REACH — Regulation (EC) No 1907/2006 — is a different shape of rule entirely. Its SVHC obligation doesn't ban anything outright; it requires you to know whether any substance on the Candidate List is present in your product above 0.1% by weight of that same article-level threshold, and if it is, to notify ECHA and be ready to tell a customer, on request, within 45 days.

The list itself is the moving part. ECHA reviews and adds to the Candidate List roughly every six months, and it's been growing steadily: an update on 4 February 2026 added two more substances, taking the total to 253 entries, with further additions confirmed later in the year. A product that cleared SVHC screening cleanly at launch can fall out of compliance eighteen months later purely because the list moved, with no change to the product itself. That's the practical difference from RoHS in one sentence: RoHS is a fixed exam you sit once per product design; REACH SVHC is a subscription you have to keep renewing.

The core difference, side by side

RoHS (Directive 2011/65/EU):

• A restriction — ten substances are banned outright above their thresholds
• Scope is electrical and electronic equipment specifically
• The substance list is fixed; it hasn't changed since the phthalate additions
• Non-compliance means the product cannot legally be placed on the market
• Assessed per homogeneous material, at 0.1% (0.01% for cadmium)

REACH SVHC (Regulation EC 1907/2006):

• A disclosure duty — substances aren't banned, but their presence must be declared
• Scope is any article placed on the EU market, not just electronics
• The Candidate List grows roughly twice a year and currently runs to 253 entries
• Non-compliance means a failure to notify and disclose, not an automatic market ban
• Assessed per article, at 0.1% by weight

Where the two actually overlap

The overlap that trips people up is substance duplication. Some of the four phthalates RoHS restricts outright — DEHP and DBP among them — also sit on the REACH Candidate List, which means a single ingredient can trigger obligations under both regimes at once, with different thresholds and different consequences for each. Passing your RoHS test on a phthalate doesn't automatically clear your REACH disclosure duty for it, and vice versa, because you're answering two different legal questions: "is this substance present above the RoHS ban threshold" is not the same question as "is this substance present above the REACH disclosure threshold," even when the number happens to be 0.1% in both cases.

Our REACH SVHC guide covers the disclosure mechanics in more detail — worth reading alongside this if you're building the checklist for a specific product.

Do you need both?

For most electronics manufacturers selling into the EU or Great Britain, yes. RoHS applies if your product falls within its equipment categories (which now cover almost all electrical and electronic goods since the "open scope" extension). REACH SVHC applies far more broadly — it isn't limited to electronics at all, so a plastic phone case, a metal bracket or a textile accessory can trigger REACH obligations even where RoHS doesn't apply because the item itself isn't electrical.

A practical way to think about it: ask "is this an electrical or electronic product?" first. If yes, RoHS applies, full stop, and you test against the fixed ten-substance list. Then, separately, ask "does any article in this product — electronical or not, packaging included — contain a Candidate List substance above 0.1%?" That second question has to be re-asked every time the Candidate List updates, which is the part manufacturers most often let slip once the initial compliance push is behind them.

As one compliance reviewer we work with put it, reviewing a client's supplier declarations: "the RoHS test certificate from two years ago is still valid evidence for RoHS — nothing there has changed. But treating that same certificate as proof of REACH compliance today is the mistake, because the Candidate List it was checked against is a third smaller than the one that's actually in force now."

Building the evidence file for both

The practical answer isn't two separate compliance projects — most of the groundwork is shared. What differs is the cadence:

• Collect substance declarations from every supplier at the homogeneous-material level, not just the finished-product level, so you can answer both RoHS and REACH questions from the same source data
• Run your RoHS check once per product design, and re-check only when the bill of materials changes
• Run your REACH SVHC screen at the same time, then set a recurring reminder for each Candidate List update — roughly every six months — rather than treating it as a one-off
• Keep both results in your technical file alongside your Declaration of Conformity, since RoHS is one of the directives a CE-marked electronic product typically declares against, even though REACH SVHC disclosure sits outside the CE marking framework itself
• Note the date of your last SVHC screen against the list version you checked, so a customer's 45-day disclosure request doesn't catch you working from stale data

None of that requires new lab work most of the time — a supplier's existing test data usually answers both questions, provided you know which threshold you're checking it against.

If you haven't mapped which regulations apply to your specific product yet, our free requirements checker will tell you in a couple of minutes whether RoHS, REACH SVHC, or both, are actually in scope before you spend time chasing supplier paperwork you might not need.

FAQ

Is REACH the same as RoHS? No. RoHS bans ten specific substances above a fixed threshold in electrical and electronic equipment. REACH's SVHC obligation is a disclosure duty tied to a much longer, growing list of substances, and it applies to articles generally, not just electronics.

Do I need to comply with both REACH and RoHS? If your product is electrical or electronic, RoHS almost certainly applies. REACH SVHC applies more broadly again, to any article containing a Candidate List substance above 0.1% by weight, electronic or not — so most hardware manufacturers need to satisfy both.

How often does the REACH SVHC list change? ECHA typically updates the Candidate List twice a year. It stood at 253 substances after the February 2026 update, with further additions confirmed later in the year, so a screening result from even twelve months ago should be treated as out of date.

Does passing RoHS testing also cover my REACH obligations? No. A RoHS test certificate proves your product is below the RoHS ban thresholds for its ten restricted substances. It does not prove you've screened against the REACH Candidate List, which contains substances RoHS doesn't cover at all, checked against a different legal threshold.

What's the penalty for missing a REACH SVHC update? It varies by member state, but the underlying failure is a notification and disclosure breach rather than an automatic product ban — though enforcement authorities can still treat it as a market surveillance issue if a customer's disclosure request goes unanswered within the 45-day window.

Whichever combination applies to your product, the two regimes are worth tracking separately rather than folding into a single "chemicals" checkbox — one is fixed, one moves, and conflating them is how a compliant product quietly drifts out of compliance without anyone touching the bill of materials.