RoHS vs REACH: Differences, Overlap and What US Buyers Must Do

RoHS and REACH are both European Union rules on hazardous substances, but they regulate different things. RoHS restricts ten named substances in electrical and electronic equipment. REACH is a much wider chemicals regime that reaches substances, mixtures and many ordinary articles. If you sell or ship a product into the EU, you may owe compliance under both. Neither is a US federal law, though US rules sit alongside them.

Key takeaways

• RoHS is product-specific, REACH is horizontal. RoHS covers electrical and electronic equipment (EEE). REACH covers substances on their own, in mixtures and in articles across nearly every industry.
• They overlap, and the stricter limit wins. A RoHS exemption never weakens protection that REACH gives.
• The US does not require EU RoHS or REACH, but EU-bound products do. US-based makers are pulled in through an EU importer, an authorized representative or their own EU sales.
• Paperwork differs. RoHS leads to CE marking, a declaration of conformity and technical documentation. REACH leads to registration duties and supply-chain communication about Candidate List substances.
• For parts built in China, ask for material data before you order. Compliance is easiest to prove when it is specified at the quote stage.

Table of Contents

• RoHS vs REACH at a glance
• What RoHS is
• What REACH is
• Where RoHS and REACH overlap
• Compliance duties compared
• Is REACH mandatory?
• Does the US require RoHS?
• Is REACH being revised?
• Which one applies to my product?
• Our perspective: compliance starts at the quote
• Getting compliant parts from WJ Prototypes
• FAQ
• Sources

RoHS vs REACH at a glance

What RoHS is

RoHS stands for Restriction of Hazardous Substances. The European Commission’s RoHS page lists ten restricted substances in electrical and electronic equipment: lead, cadmium, mercury, hexavalent chromium, PBB, PBDE, and four phthalates (DEHP, BBP, DBP and DIBP).

The limits apply to each homogeneous material, meaning any single material that cannot be mechanically separated into different materials. The Commission’s guidance sets the maximum at 0.1% for lead, mercury, hexavalent chromium, PBB and PBDE, and 0.01% for cadmium. That is why a solder joint, a plating layer and a plastic housing are each judged on their own, not as one averaged product.

What RoHS excludes

RoHS applies to the Annex I equipment categories unless specifically excluded. ECHA’s legislation profile lists exclusions including military and security equipment, space equipment, certain fixed installations and industrial tools, means of transport, professional non-road mobile machinery, active implantable medical devices, photovoltaic panels, research and development equipment and pipe organs. Batteries used in EEE are outside RoHS too, and are handled under battery legislation.

If your product is a gray area, such as a machine that is partly industrial and partly consumer, read the Annex I categories and the exclusions before assuming either way.

What REACH is

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. Ireland’s EPA describes it as a general chemicals regime covering virtually all substances, hazardous or not, that are manufactured, imported or used in the EU. RoHS, by contrast, is sector-specific.

Four working pieces matter to a manufacturer:

1. Registration. ECHA explains that EU importers of substances or mixtures generally must register each substance at one tonne or more per year before importing.
2. Candidate List (SVHC) communication. ECHA’s article guidance says a supplier must tell recipients when an article contains a Candidate List substance above 0.1% weight by weight of that article, giving at least the substance name. Consumers can request the same information.
3. Notification. An EU importer of such articles may also have to notify ECHA when the quantity exceeds one tonne per producer or importer per year.
4. Authorization and restriction. Some substances are restricted outright or need permission for specific uses.

The 0.1% threshold is counted per article, not per finished product. For an imported product made of several articles, the importer must check each article. A screw, a gasket and a housing are three separate checks.

Because REACH works through the supply chain, the quality of your suppliers’ chemical data matters. If you source coatings, additives or plastics yourself, it helps to qualify additive suppliers before the first order, so the substance information you pass downstream is real.

Where RoHS and REACH overlap

The two regimes are not alternatives. The Commission’s common-understanding paper says their scopes partially overlap because REACH applies to substances in articles, including EEE that falls under RoHS. It adds that RoHS should generally take priority on questions specifically about substance use in EEE.

The Commission’s RoHS FAQ is clear on the practical rule: RoHS does not displace REACH. Where both restrict a substance, the strictest restriction, meaning the lowest maximum concentration, applies. A RoHS exemption cannot weaken REACH protection.

The Commission’s 2023 RoHS evaluation found both observed and potential overlap between RoHS restrictions and REACH restrictions and authorizations. It puts this down to the different legislative purposes and methods of the two laws.

In practice, a circuit board can pass RoHS yet still carry a Candidate List substance above 0.1% in a plastic part, which triggers a REACH notice. Passing one does not clear the other.

Compliance duties compared

RoHS paperwork

RoHS is product legislation with harmonized conformity assessment and market surveillance. Per the 2023 evaluation, evidence includes CE marking, an EU declaration of conformity and technical documentation. The same report names checking CE marking and technical documentation as an economical enforcement method, so expect market authorities to ask for them first. The Commission also identifies a harmonized standard for technical documentation used to assess materials, components and EEE.

If a specific application cannot yet avoid a restricted substance, an exemption can be requested. Applications need supporting evidence such as substitute-suitability tests, technical or scientific data, supplier evidence on substitutes, relevant REACH documentation and socio-economic data. Most prototype teams never get here, because designing around the substance is faster.

REACH paperwork

REACH duties are triggered by what you import or supply, not by an industry label. Documents typically include registration dossiers (for qualifying substances), safety information passed down the chain, and written SVHC notices for articles. Many buyers meet REACH first as a supplier declaration or statement of compliance requested by an EU customer.

Is REACH mandatory?

For products placed on the EU market, yes, but the duties fall on specific parties. ECHA states that obligations rest on EU importers or an appointed only representative when triggered. A non-EU manufacturer is affected through that importer or representative, and ECHA recommends tracking the Candidate List and giving substance information to EU customers.

On the RoHS side, the Commission’s page says all products with an electrical or electronic component have to comply unless specifically excluded.

Does the US require RoHS?

Not at the federal level. The US has no national law equivalent to EU RoHS. Three things still matter to American buyers:

• TSCA. US EPA explains that the Toxic Substances Control Act is the federal framework for evaluating and managing chemical risks, and it includes import certification. Imports of chemical substances or mixtures generally need positive or negative TSCA certification. For chemicals in articles, certification applies only under a specific TSCA rule. The importer or authorized agent files with Customs and Border Protection.
• California. The state’s RoHS law prohibits selling a covered electronic device that cannot be sold in the EU because of high concentrations of hazardous substances such as lead, mercury, cadmium and hexavalent chromium. It is modeled on the EU directive.
• Customer contracts. Many US OEMs, especially in electronics, require RoHS and REACH statements from suppliers whatever the law says.

So a US company needs EU RoHS and REACH compliance when it sells into the EU, directly or through a distributor, and often when a large customer demands it.

Is REACH being revised?

A comprehensive REACH revision had been expected for years. A compliance consultancy reported that the Environment Commissioner told the European Parliament’s environment committee on 27 April 2026 that the full revision would not go ahead. Targeted changes can still happen, and the Candidate List keeps growing, so check ECHA for the current state before you fix a compliance plan.

Which one applies to my product?

Work through these questions in order:

1. Will it be sold, or shipped, into the EU? If not, EU rules do not apply, though California or customer requirements might.
2. Is it electrical or electronic equipment? If yes and not excluded, RoHS applies. Check the exclusions, including R&D equipment and means of transport.
3. Does any article exceed 0.1% of a Candidate List substance? If yes, REACH communication duties apply, whether or not RoHS does.
4. Do you import substances or mixtures, such as resins or coatings, in volume? Check registration thresholds with your EU importer.
5. Who holds the documents? Decide early who writes the declaration and who stores the technical file.

A purely mechanical part, such as a CNC bracket for a pump, is outside RoHS but still within REACH as an article. A sensor housing that ships inside a consumer device is inside both.

Our perspective: compliance starts at the quote

Most compliance problems we see start as specification gaps. A drawing says “anodize, black” or “ABS-like resin” and nobody asks which chemistry, which supplier, which certificate. Months later an EU customer asks for a declaration and nobody can produce one.

Our advice is to settle three things before ordering prototypes. Name the destination market. Name the standard you expect, RoHS, REACH or both. Ask the manufacturer for material and finish data tied to the actual job, not a generic certificate. Because we run SLA, SLS, MJF, DMLS, CNC machining, sheet metal, vacuum casting, injection molding and die casting under ISO certification, with a dedicated project manager on each job, we can ask those questions of materials and finishes at the quote stage, when changing them costs nothing.

We also suggest treating prototypes as the test run for compliance. If a plated finish or a resin grade will carry a restricted substance, you want to learn that on the ten-unit run, not the ten-thousand-unit one. For a wider view of sourcing in China, read our RoHS and REACH guide for Western brands, and for finishes and materials in electronics, our guide to ESD safe materials.

— Nas

Getting compliant parts from WJ Prototypes

If your parts are headed for an EU-compliant product, tell us the target market and the standards at the quote stage. Upload your files for an instant quote on CNC machining, or choose from our injection molding, sheet metal and 3D printing services. There is no minimum order quantity, so you can validate materials on a single unit. Electronics teams can also see how we support consumer electronics prototypes and low-volume production.

FAQ

What is the difference between RoHS and REACH?

RoHS restricts ten named hazardous substances in electrical and electronic equipment. REACH is a broad chemicals regulation covering registration, evaluation, authorization and restriction of substances on their own, in mixtures and in articles. RoHS is about what goes into one product category, REACH about chemicals across the whole economy.

Is REACH mandatory in the EU?

Yes, for products and substances placed on the EU market, but the duties fall on defined parties such as EU importers and only representatives. Some obligations, like SVHC communication, apply to article suppliers once a Candidate List substance passes 0.1% weight by weight of an article. A non-EU manufacturer is usually affected through its EU importer.

Does the US require RoHS?

There is no federal RoHS in the US. California has its own RoHS law for covered electronic devices, and TSCA governs chemical imports. If you sell into the EU, EU RoHS applies to your electronics regardless of where you are based.

Do RoHS and REACH apply to the same product?

Often, yes. REACH applies to substances in articles, including electronics that fall under RoHS. Where both restrict a substance, the stricter limit applies, and a RoHS exemption never lowers REACH protection.

Sources

• RoHS Directive, European Commission
• RoHS guidance document, European Commission
• RoHS FAQ key guidance document, European Commission
• RoHS legislation profile, ECHA
• POPs, REACH and RoHS differences, Ireland EPA
• REACH and CLP for non-EU companies, ECHA
• Guidance on requirements for substances in articles, ECHA
• REACH and RoHS: a common understanding, European Commission
• Commission report on the RoHS evaluation, 2023
• RoHS harmonized standard, European Commission
• Learn about TSCA, US EPA
• TSCA requirements for importing chemicals, US EPA
• California RoHS in electronic devices, DTSC
• REACH revision put on hold, CIRS Group

Recommended

• RoHS vs REACH: A Compliance Guide for Western Brands Sourcing in China
• U.S. CNC Shops: 3 Procurement Checks for ITAR Machining Compliance