RoHS vs REACH: A Compliance Guide for Western Brands Sourcing in China

Whether RoHS or REACH applies to your product depends on two things: what the product is, and who is legally responsible in the destination market. Get those two questions wrong and you are looking at customs seizures, marketplace delisting, or a recall. Here is the short operational answer, then the full playbook.

Three immediate actions for procurement:

1. Map your SKUs. Classify each product as electrical and electronic equipment (EEE), an "article" under REACH, or both. Cables, PCBs, and consumer electronics are almost always both. A steel fastener is likely REACH-only.
2. Request supplier evidence. For every EEE item: a RoHS Declaration of Conformity (DoC), homogenous-material test reports, Safety Data Sheets (SDS), and a Substance of Very High Concern (SVHC) declaration. For articles: an SVHC communication letter and, where applicable, a CoC.
3. Flag importer/OR obligations. Identify which SKUs need an EU-established importer or an appointed Only Representative (OR) before the first shipment crosses the border.

Quick triage by risk tier:

• High risk: cables, plastic housings, coatings, printed circuit boards, connectors with polymer insulation
• Medium risk: metal connectors, electromechanical components, plated metal parts
• Low risk: pure mechanical steel or aluminum structural parts with no surface treatment

Run this triage before your next RFQ goes out. The sections below explain exactly what each regime requires and how to build the documentation chain.

Key Takeaways

Navigating RoHS vs REACH when sourcing in China requires separate verification for each regime, a supplier contract with change-notification and right-to-test clauses, and a live monitoring system for ECHA Candidate List updates and GB 26572-2025 transition dates.

Table of Contents

• 1. What RoHS actually covers — EU vs China, substances and thresholds
• 2. What REACH requires — and why it applies even when you manufacture outside the EU
• 3. RoHS vs REACH side-by-side — where they overlap and where they diverge
• 4. China RoHS in 2026: GB 26572-2025, EFUP labeling, and the deadlines you cannot miss
• 5. Procurement compliance checklist for sourcing from China — step by step
• 6. How to read lab reports and what counts as acceptable evidence
• 7. Only Representative vs EU importer — which route makes more sense for your situation
• 8. Common pitfalls and enforcement risks when sourcing from China
• 9. What compliant factories actually do — a supplier-side checklist
• WJ Prototypes makes compliance-ready sourcing from China straightforward

1. What RoHS actually covers — EU vs China, substances and thresholds

RoHS restricts specific hazardous substances in electrical and electronic equipment. The EU version (Directive 2011/65/EU, amended by 2015/863/EU) applies to any EEE placed on the EU market, regardless of where it was manufactured. China's version has historically worked differently, using a catalogue-based approach, but that is changing fast.

Restricted substances and thresholds (both EU and China RoHS):

• Lead (Pb): max 0.1% by weight per homogenous material
• Mercury (Hg): 0.1%
• Hexavalent chromium (Cr6+): 0.1%
• Polybrominated biphenyls (PBB): 0.1%
• Polybrominated biphenyl ethers (PBDE): 0.1%
• Cadmium (Cd): 0.01% (stricter threshold)
• Four phthalates (DEHP, BBP, DBP, DIBP): 0.1% each (added by EU amendment; now also added to China RoHS under GB 26572-2025)

EU RoHS vs China RoHS — key differences:

China's MIIT (Ministry of Industry and Information Technology) and SAMR (State Administration for Market Regulation) jointly oversee China RoHS enforcement. Until now, China RoHS was largely voluntary for products outside the catalogue. GB 26572-2025 changes that, and the transition window is shorter than many procurement teams realize.

2. What REACH requires — and why it applies even when you manufacture outside the EU

REACH (Regulation (EC) No 1907/2006) is not a product safety directive. It is a chemicals management regulation that covers the registration, evaluation, authorization, and restriction of chemical substances. Its reach extends to any substance, mixture, or article imported into the EU, regardless of where it was made.

The core obligations that hit Western brands sourcing from China:

• Registration: Any substance imported into the EU at or above 1 tonne per year must be registered under REACH. The obligation falls on the EU-established importer or an appointed OR.
• SVHC communication: If an article contains an SVHC above 0.1% by weight, the supplier must communicate that information to the recipient. Under Article 33 of REACH, this is mandatory — not optional.
• Article 7(2) notification: If an SVHC is present above 0.1% w/w in an article and the total quantity exceeds 1 tonne per year across all articles, the importer must notify ECHA.
• CLP (Classification, Labeling and Packaging): Governs hazard communication for substances and mixtures. Relevant for any chemical inputs in your supply chain.

The 0.1% w/w SVHC threshold applies to the article as a whole, not per component. ECHA's guidance on substances in articles clarifies this: if a cable contains a plasticizer that is an SVHC and that plasticizer exceeds 0.1% of the cable's total weight, the communication obligation is triggered.

ECHA's guidance for non-EU companies is explicit: the legal responsibility sits with whoever is established in the EU. If your Chinese supplier ships directly to an EU customer, that EU customer becomes the importer and carries the REACH burden. If you are a US brand selling into the EU through a distributor, your distributor is the importer unless you appoint an OR.

The ECHA Candidate List currently contains over 240 SVHCs and is updated twice yearly. Several substances that appear on the RoHS restricted list — including certain phthalates — also appear on the Candidate List or in REACH Annex XVII. Compliance with one regime does not satisfy the other.

3. RoHS vs REACH side-by-side — where they overlap and where they diverge

The two regimes share some substance overlap but operate on entirely different legal logic. A product can be RoHS-compliant and still trigger REACH obligations, and vice versa.

Two real-world interaction cases:

The cable triggers both regimes simultaneously.

A zinc die-cast connector housing: RoHS likely does not apply unless the connector is part of an EEE assembly. Check the REACH restricted substances list before assuming metal parts are clean.

The practical takeaway: run both checks independently for every SKU. A clean RoHS test report is not a REACH clearance.

4. China RoHS in 2026: GB 26572-2025, EFUP labeling, and the deadlines you cannot miss

China's GB 26572-2025 is the country's first mandatory national RoHS standard. Published August 1, 2025, it replaces the previous voluntary framework and brings Chinese enforcement materially closer to EU levels.

What GB 26572-2025 changes:

• Adds four phthalates (DEHP, BBP, DBP, DIBP) to the restricted substance list, matching EU RoHS
• Specifies testing methods via the GB/T 39560 series, replacing the patchwork of previous methods
• Introduces a two-category product structure:

Critical dates:

• August 1, 2025: GB 26572-2025 published
• August 1, 2027: Mandatory implementation date — products must comply with the new standard
• August 1, 2028: Inventory disposal deadline — non-compliant stock produced before the implementation date must be cleared from the market

The draft 2025 catalogue expansion proposed by MIIT and SAMR adds home appliances, wearable electronics, IT and networking equipment, medical devices, and industrial equipment to the scope of Category I. If your product falls into any of these categories, the August 2027 deadline is not theoretical.

EFUP labeling under SJ/T 11364:

The Environmental Friendly Use Period mark must appear on the product itself or on its packaging where direct marking is impractical. The mark shows a number inside a green circle indicating the number of years the product can be used without releasing hazardous substances above threshold levels. Procurement teams need to confirm that Chinese suppliers are applying the correct EFUP period and that the mark format complies with SJ/T 11364, not just a generic green symbol.

Mondaq's analysis of GB 26572-2025 notes that conformity assessment requirements for catalogue products will also tighten, meaning self-declaration alone may not be sufficient for Category I items going forward.

Pro Tip: Build the August 2027 implementation date into your production planning now. Any tooling or material changes needed to meet GB 26572-2025 substance limits take time to validate. If you are sourcing materials for CNC-machined or die-cast components, confirm with your supplier that their material stock will be GB 26572-2025 compliant before the transition date, not after.

5. Procurement compliance checklist for sourcing from China — step by step

This is the operational sequence. Work through it for every new supplier and every new SKU.

Step 1: Product scoping

1. Classify the product: EEE (triggers RoHS), article (triggers REACH), or both.
2. Check whether the product falls within the China RoHS Compliance Management Catalog (Category I) or is Category II only.
3. Identify the EU importer of record or confirm whether an OR appointment is needed.

Step 2: Supplier pre-screening

1. Ask whether the supplier holds ISO/IEC 17025-accredited lab access or works with a CNAS-accredited third-party lab (SGS, Intertek, or equivalent).
2. Request the supplier's most recent RoHS test report for a comparable product — check the lab name and accreditation number before reading the results.
3. Confirm the supplier has a documented material change-notification process.

Step 3: Initial document request

1. RoHS Declaration of Conformity (DoC) — must reference the specific product model/part number.
2. Homogenous-material test reports per IEC 62321 (EU) or GB/T 39560 (China) — sample IDs must match the product.
3. SDS for any chemical inputs or surface treatments.
4. SVHC declaration covering the current ECHA Candidate List version.
5. Certificate of Conformity (CoC) for the specific production batch.

Step 4: Operational controls

1. Insert a mandatory material declaration form into your purchase order template — suppliers complete it for every new material or component.
2. Add a change-notification clause: supplier must notify you in writing at least 30 days before any material, process, or sub-supplier change.
3. Add a right-to-test clause: you reserve the right to commission third-party testing on any batch at your cost, with supplier cooperation required.
4. Set an audit cadence: annual for high-risk suppliers, biennial for medium-risk.
5. Retain all compliance documents for a minimum of 10 years (EU RoHS requirement for technical documentation).

Sample contract clause (copy-ready):

Pro Tip: Attach a one-page compliance checklist to every RFQ. Suppliers who cannot complete it at the quoting stage will not complete it after the order is placed. Use the checklist as a pre-qualification filter, not a post-award formality. For sourcing guidance that integrates compliance into the QC workflow, the CNC machining sourcing guide covers the operational steps in detail.

6. How to read lab reports and what counts as acceptable evidence

A test report from a non-accredited lab is not evidence; it is a piece of paper. Procurement teams need to know exactly what makes a report valid before accepting it.

Acceptable documents and what to check in each:

How to verify lab accreditation:

• For CNAS-accredited labs: search the CNAS website by lab name or certificate number.
• For ISO/IEC 17025-accredited labs outside China: check the national accreditation body (A2LA in the US, UKAS in the UK, DAkkS in Germany).
• SGS and Intertek both hold broad ISO/IEC 17025 accreditation scopes covering RoHS test methods.

Red flags that should stop a shipment:

• Test report dated more than 12 months ago with no re-test since a material change
• Product description on the report is generic ("electronic component") rather than matching your specific part number
• Lab name is not searchable in any accreditation database
• Report covers the assembled product only, with no homogenous-material breakdown
• SVHC declaration references an outdated Candidate List version (ECHA updates twice yearly)

Compliance failures often stem from test reports that are not product-specific or were produced by non-accredited labs. A $500 third-party spot-check is cheaper than a customs hold.*

7. Only Representative vs EU importer — which route makes more sense for your situation

If you are a US brand selling into the EU and your Chinese manufacturer ships directly to EU customers or distributors, someone in the EU is the importer and carries REACH registration obligations. You have two options: let your EU distributor carry that burden, or appoint an Only Representative.

What an Only Representative does:

An OR is a legal entity established in the EU that a non-EU manufacturer appoints to fulfill REACH obligations on its behalf. The OR submits registration dossiers to ECHA, handles SVHC notifications, maintains records in REACH-IT, and communicates substance information down the supply chain. EU importers of the manufacturer's products are then relieved of direct registration duties for those substances.

Pros of appointing an OR:

• Protects your formulation confidentiality — the OR registers without disclosing full composition to EU importers
• Centralizes registration management across multiple EU importers
• Reduces the administrative burden on your distribution partners, which can be a commercial advantage
• Gives you direct control over the registration dossier and notification timeline

Cons and limits:

• Administrative cost: OR services typically involve setup fees and annual maintenance costs
• One OR per manufacturer per substance registration — you cannot split registrations across multiple ORs for the same substance
• The OR must be established in the EU (EEA), not just operating there
• You remain responsible for ensuring the OR has accurate and complete substance data

Steps to appoint an OR:

1. Identify an EU-established OR service provider (law firms, specialist consultancies, and testing bodies like SGS offer OR services).
2. Execute a formal OR appointment agreement that specifies the substances, products, and registration scope.
3. Provide the OR with complete substance composition data, SDS, and any existing registration dossiers.
4. Notify your EU importers in writing that an OR has been appointed and that they are relieved of direct registration duties for the covered substances.
5. Collect and retain the OR appointment agreement and registration dossier reference numbers as part of your compliance file.

ECHA's guidance for non-EU companies explains the OR mechanism in detail and is the authoritative reference for appointment requirements.

8. Common pitfalls and enforcement risks when sourcing from China

Most compliance failures are not caused by deliberate fraud. They happen because procurement accepted paperwork at face value, or because nobody tracked the ECHA Candidate List updates between supplier qualification and the next shipment.

The most common failure modes:

• Generic test reports: A report that covers "LED lighting products" does not cover your specific SKU. Customs authorities and market surveillance inspectors check sample IDs.
• Ignoring Candidate List updates: ECHA adds substances to the Candidate List twice a year. A supplier SVHC declaration from 18 months ago may not cover substances added since then.
• Expired RoHS exemptions: EU RoHS includes time-limited exemptions for specific applications (e.g., lead in certain solder alloys). Exemptions expire and are not automatically renewed. Check the current exemption status before relying on one.
• Incorrect EFUP labeling: A missing or wrong EFUP period on a product destined for the Chinese market can trigger rejection at Chinese customs or marketplace delisting on platforms like JD.com or Tmall.
• Sub-supplier changes: Your direct supplier passes RoHS testing, then switches a component from a sub-supplier without notifying you. The change-notification clause in your contract is the only protection against this.

Enforcement triggers to know:

• EU customs authorities conduct random sampling of imported EEE at ports of entry. A failed test triggers a market ban and potential recall.
• SAMR conducts market surveillance in China and can order product removal and fines for non-compliant EFUP labeling or catalogue products that fail substance limits.
• Online marketplaces (Amazon EU, for example) increasingly require RoHS DoCs and REACH SVHC declarations as a condition of listing.

Immediate mitigations when a red flag appears:

• Hold the shipment and commission third-party testing before customs clearance if you have any doubt about a test report's validity.
• Issue a formal corrective action request to the supplier with a 30-day response deadline.
• Check whether the affected SKU is covered by an active RoHS exemption and whether that exemption is still valid.
• If a recall is triggered, document the batch numbers, notify your EU importer or OR immediately, and preserve all compliance records.

Pro Tip: Set a calendar alert for every ECHA Candidate List update (typically June and December). When a new substance is added, run it against your active supplier SVHC declarations within 30 days. This takes less than an hour and prevents the most common compliance gap in ongoing supplier relationships. Compliance integration into manufacturing operations is what separates reactive from resilient supply chains.

9. What compliant factories actually do — a supplier-side checklist

When you visit or audit a supplier, you are looking for evidence that compliance is built into the production process, not assembled after the fact when a customer asks for paperwork.

Factory processes that signal genuine compliance readiness:

• Incoming material controls: Suppliers should test or verify incoming raw materials and components against a restricted substance list before they enter production. Ask to see incoming inspection records.
• BOM-level SVHC screening: A compliant supplier maintains a bill of materials with substance-level data, not just component names. Each material entry should flag whether it contains any SVHC above 0.1%.
• Homogenous-material sampling: Samples are taken from specific material layers or components, not from the finished product as a whole. Ask which lab performs the testing and request the accreditation certificate.
• EFUP labeling workflow: For products destined for the Chinese market, the supplier should have a documented process for determining the correct EFUP period and applying the SJ/T 11364-compliant mark.
• Batch traceability: Test records should be traceable to specific production batches by date and batch number, not just to a product model.
• Change management: Any material or sub-supplier change should trigger an internal review and customer notification before the change is implemented.

A supplier-side compliance workflow that integrates BOM-level SVHC screening, homogenous-material sampling, and EFUP labeling at product-design checkpoints reduces the need for costly rework after production starts. Catching a non-compliant plasticizer at the material approval stage costs a fraction of what it costs to rework or scrap a finished batch.

Supplier questionnaire — send this before qualification:

• Does your facility hold ISO/IEC 17025 accreditation or work with a CNAS-accredited third-party lab? Please provide the accreditation certificate number.
• Can you provide a recent homogenous-material test report for a comparable product, with sample IDs matching the production batch?
• Do you maintain a BOM-level SVHC declaration covering the current ECHA Candidate List?
• What is your process for notifying customers of material or sub-supplier changes?
• How do you manage inventory of products produced before and after a regulatory transition date (e.g., GB 26572-2025 implementation)?
• Can you provide evidence of EFUP labeling compliance per SJ/T 11364 for products in the China RoHS catalogue?

WJ Prototypes integrates these controls into its production planning and documentation handoffs, giving Western brands a single compliance-evidence package — test reports, material declarations, and EFUP labeling records — ready for EU importer review. For high-consequence applications, the aerospace CNC sourcing guide explains how supplier qualification and traceability practices apply to precision parts.

The compliance gap most procurement teams underestimate

The hardest part of RoHS and REACH compliance is not understanding the rules. The rules are documented, the thresholds are clear, and the test methods are specified. The hard part is maintaining compliance across a live supply chain where materials change, Candidate Lists update, and suppliers switch sub-suppliers without telling you.

Most procurement teams treat compliance as a qualification event: get the documents, file them, move on. That works until a new SVHC lands on the Candidate List, or a supplier quietly changes a plasticizer formulation, or an exemption expires. At that point, the paperwork in your files is no longer accurate, and you have no mechanism to know it.

The contract clauses in this guide — change notification, right to test, indemnity — are not legal formalities. They are the only operational mechanism that keeps your compliance status current between audits. Pair them with a twice-yearly Candidate List review and random batch testing, and you have a system that actually holds. Without them, you have a snapshot that ages out the moment the ink dries.

The resources required to do this well are real: budget for third-party testing, legal review of contract language, and at least one person whose job includes tracking regulatory updates. Treat those as fixed costs of market access, not optional overhead. The supplier-side readiness checklist in Section 9 is a good starting point for your next supplier audit.

WJ Prototypes makes compliance-ready sourcing from China straightforward

Getting clean documentation from a Chinese manufacturer is often the bottleneck that delays EU market entry. WJ Prototypes addresses that directly: as an ISO-certified manufacturer with access to CNAS-accredited lab partners, WJ Prototypes coordinates pre-production compliance checks, homogenous-material testing, EFUP labeling workflows, and documentation bundling so your EU importer gets a complete evidence package with every order.

Procurement teams get a single point of contact for RoHS DoCs, SVHC declarations, SDS, and batch-linked test reports — plus sample contract clause templates adapted for manufacturing in China. Whether you need a prototype validated for EU market entry or a low-volume production run with full compliance documentation, WJ Prototypes has the engineering and QA infrastructure to support it. Request a compliance-ready quote or upload your BOM for a compliance review.

Sources

Keep these official and authoritative references accessible and set up alerts where the platforms support them:

• REACH and CLP for non-EU companies - ECHA
• Guidance on requirements for substances in articles | ECHA
• Substances restricted under REACH | ECHA
• Regulation (EC) No 1907/2006 (REACH) — EUR-Lex

This article is general information, not a substitute for advice from a qualified lawyer. Consult a qualified legal professional about your own circumstances before acting on anything here.

FAQ

Are REACH and RoHS the same regulation?

No. RoHS restricts specific hazardous substances in electrical and electronic equipment; REACH is a broader chemicals regulation covering registration, evaluation, authorization, and restriction of substances in all products imported into the EU. Compliance with one does not satisfy the other.

What are the RoHS requirements in China under GB 26572-2026?

GB 26572-2025, mandatory from August 1, 2027, restricts 10 substances (including four phthalates added to match EU RoHS) in products listed in the Compliance Management Catalog, requires homogenous-material testing per the GB/T 39560 series, and mandates EFUP labeling per SJ/T 11364 for all covered products.

What is the key difference between EU RoHS and China RoHS?

EU RoHS applies to all EEE placed on the EU market regardless of product category; China RoHS uses a catalogue-based approach where Category I products must meet both substance limits and EFUP labeling requirements, while Category II products require labeling only. GB 26572-2025 is bringing the two systems closer in substance scope but the enforcement structure and labeling requirements remain distinct.

What does the RoHS symbol in China look like?

The China RoHS mark is the EFUP (Environmental Friendly Use Period) symbol: a number inside a green circle indicating the years the product can be used without releasing hazardous substances above threshold levels, applied per SJ/T 11364. It is different from the EU CE mark and must appear on the product or its packaging.

When does an SVHC trigger a REACH notification obligation?

If the total quantity of articles containing that SVHC exceeds 1 tonne per year, the EU importer or appointed Only Representative must also notify ECHA under Article 7(2) of the REACH Regulation.

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