REACH vs RoHS Compliance: Which Should You Choose?

REACH vs RoHS Compliance: Which Should You Choose?

When importing electric and electronic products into the EU, it is important to consider two common product certifications: REACH and RoHS. It is easy to confuse the two and make mistakes, so this article will explain REACH and RoHS compliance and highlight the key differences between RoHS and REACH.

• What is RoHS?
• What is REACH?
• Difference Between RoHS and REACH

What is RoHS?

RoHS stands for Restriction of Hazardous Substances in Electrical and Electronic Equipment. This EU directive aims to reduce the impact of EEE products on the environment and human health by restricting the content of 10 harmful substances. RoHS compliance is mandatory for EEE products sold in the EU. If your product is not RoHS compliant, it will be required to withdraw from the EU market and may face massive fines or even imprisonment.

What is REACH?

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

• The annual usage of the substance exceeds 1 ton.
• The substance content in the product is more than 0.1%.
• The substance is not registered for this use.

Without REACH registration, your products will be banned from selling in the EU. Types of products that require registration include chemical substances themselves, chemical mixtures such as toothpaste and shoe polish, and products that intentionally release chemical substances for additional functions such as scented erasers. The registrant should be the manufacturer or importer in the EU.

Documents for registration should include information about hazardous substances, the risks when using them, and how to control and deal with these risks. In addition, if the annual production or import volume of chemical substances exceeds 10 tons, you also need to submit a chemical safety report.

If your product only meets the condition that the SVHC substance content exceeds 0.1%, you do not need to register. You just label the substances that exceed the standard and their impacts as required in a conspicuous place on the product packaging. And then prepare relevant documents such as MSDS reports to ensure that the product is safe to use. In this way, you could still sell your products in the EU.

Evaluation

Evaluation includes dossier evaluation and substance evaluation.

For dossier evaluation, the European Chemicals Agency (ECHA) will evaluate at least 5% of the dossier that gets submitted for registration. It aims to ensure the completeness and accuracy of the information. If it is not complete, ECHA will inform the register of what else is needed.

For substance evaluation, its purpose is to identify the risks of chemical substances to human health and the environment.

Authorization

After the evaluation is completed, the next step is authorization. Since all substances that get authorized are from the SVHC substance list, the SVHC list is also called the candidate list of those substances.

If a substance is recommended for authorization, a comment period will ensue, which lasts for 90 days.

Restriction of Chemicals

The restriction is another means under REACH that allows the European Commission to control the use of dangerous chemical substances circulated within the EU market. It regulates some chemicals that may completely get banned, or some uses of the chemicals can get restricted under a certain standard.

REACH is a regulation for the preventive management of chemicals, which ensures that chemicals safely enter the EU market, shows the risks and corresponding management measures for safe use, and aims to reduce the risks of chemicals for humans and the environment throughout the whole product life cycle.

For applicable substances, if there is no registration and compliance report, you may face product recall, fines, or criminal liability.

Difference Between RoHS and REACH

Applicable Products

RoHS tests all electric and electronic products sold in the EU market.

REACH regulates the use of harmful and toxic substances in products. So REACH covers a very wide range of goods. Except for food and pharmaceuticals, almost every product is included, such as electric products, individual chemicals, and daily consumer goods that get manufactured, imported, or sold within the EU.

Restricted Substances

RoHS tests 10 substances, such as Pb, Hg, DIBP, etc. Except for Cd, which is a maximum of 0.01%, the proportion of other substances shall not exceed 0.1%.

Compared to RoHS, REACH tests a larger scope of substances. It mainly tests if the product involves SVHC, which indicates substances that are carcinogenic, mutagenic, toxic for reproduction, or bioaccumulative, and if the SVHC content meets the REACH standard (0.1%). If it exceeds, you may need to register the substance.

Now on the SVHC list, there are more than 200 substances, including metals and chemicals. In addition, the SVHC list gets updated every 6 months. So you need to follow the latest news and update the test report if you import products into the EU.

Testing Methods

RoHS always directly conducts a chemical analysis of the same material and does not accept mixed testing for multiple materials.

In REACH testing, because the SVHC list covers many substances, it will be costly if all substances get tested individually. The generally accepted method on the market is to group and mix multiple materials for testing for products with many materials, such as TV sets.

Documents for Compliance

In RoHS testing, if your products meet the standard, the inspection company you choose will issue a RoHS compliance certificate.

In REACH testing, it will issue an SVHC testing report, which you need to perform the relevant obligations and a declaration of conformity if the test results comply with the REACH standard.

Here are the compliance certificates of RoHS and REACH for your reference.

Documents for Compliance

In the EU, both RoHS and REACH are mandatory regulations. REACH focuses on substances, while RoHS focuses on products. These two regulations do not have any effect on each other.

Please be aware that if you import electric and electronic products, both of these documents are required. If there are overlapping requirements, stricter requirements such as minimum allowable concentrations should be applied. The EU Environment Agency will also review the RoHS Directive regularly to ensure consistency with REACH regulations and maintain uniformity between them.

As a leading sourcing company, Onestopimport has helped over 4000 importers source products from China, including many from the EU. We have extensive experience in dealing with EU orders and can also assist with arranging shipments and obtaining necessary documents such as RoHS certificates and SVHC testing reports.