REACH and RoHS compliance for importers and exporters

What REACH and RoHS mean for trade teams

REACH and RoHS compliance is not a single certificate. For importers and exporters, it is a product evidence system showing whether chemicals, components and finished goods meet EU requirements before they are placed on the market. REACH is the broader chemicals regulation. It can apply to substances, mixtures and articles across many sectors, including consumer goods, machinery parts, packaging components and accessories. RoHS is narrower in scope but strict for electrical and electronic equipment, because it restricts specific hazardous substances in homogeneous materials.

In practical trade terms, a buyer may need REACH declarations, RoHS declarations, test reports, technical files and updated supplier data for the same product. The right question is not which regulation matters more, but which obligations apply to the exact product, material and route to market.

This guide is written for import and export teams that need a clear working comparison, not a legal theory paper. For broader regulatory topics, see the Compliance section.

How the two rules differ

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is built around chemical risk management across the EU market. The European Chemicals Agency, usually referred to as ECHA, maintains the Candidate List of substances of very high concern, or SVHCs, and manages REACH processes such as registration, authorisation and restriction.

RoHS stands for Restriction of Hazardous Substances. The current EU framework is Directive 2011/65/EU, as amended over time. It applies to electrical and electronic equipment unless a product or use is excluded or covered by a valid exemption. The European Commission describes RoHS as a rule that restricts certain hazardous substances in electrical and electronic equipment to improve recyclability and reduce environmental and health risks.

Substance limits that matter in sourcing

A common misunderstanding is that both regimes use the same 0.1% concept in the same way. They do not. Under REACH, suppliers of articles have communication duties when a Candidate List SVHC is present above 0.1% weight by weight in an article. ECHA guidance also treats complex products as being made of separate articles, so a small component can trigger duties even if the finished product appears to be below 0.1% overall.

In the ECHA Candidate List update dated 4 February 2026, the list contained 253 entries. ECHA’s table also stated that no new SVHC proposals were submitted during 2026 and that the next update was anticipated for June 2027. That does not mean trade teams can ignore updates. A declaration should still name the Candidate List version or date checked, because a product that was acceptable under an older list may require new communication after a list update.

RoHS uses maximum concentration values by weight in homogeneous materials. According to the European Commission and EU RoHS Annex II, the restricted substance list currently covers ten substances:

• Lead at 0.1%.
• Mercury at 0.1%.
• Cadmium at 0.01%.
• Hexavalent chromium at 0.1%.
• Polybrominated biphenyls, or PBB, at 0.1%.
• Polybrominated diphenyl ethers, or PBDE, at 0.1%.
• Bis(2-ethylhexyl) phthalate, or DEHP, at 0.1%.
• Butyl benzyl phthalate, or BBP, at 0.1%.
• Dibutyl phthalate, or DBP, at 0.1%.
• Diisobutyl phthalate, or DIBP, at 0.1%.

The difference between article-level and homogeneous-material-level assessment is not a technical footnote. It affects what suppliers must test, what buyers should request, and how a bill of materials should be reviewed.

Documents exporters should prepare before shipment

For cross-border sales, evidence is best prepared before a purchase order becomes urgent. A short declaration may be useful, but it should be backed by data that can stand up to a customer audit or market surveillance request.

For REACH, exporters commonly need a dated SVHC declaration that identifies the product, model, revision and Candidate List date. If the product contains an SVHC above the threshold, the declaration should name the substance, identify the affected article and provide safe-use information. Where substances or mixtures are supplied, safety data sheets may be required. For articles going into the EU market, suppliers should also support the EU importer with the information needed for SCIP notification when an article contains a Candidate List substance above 0.1% weight by weight.

For RoHS, exporters of EEE should prepare a RoHS declaration covering the correct product family and substance list. The technical basis may include a bill of materials, supplier declarations, material composition data, risk assessment under EN IEC 63000 principles and targeted laboratory reports. If a product relies on a RoHS exemption, the file should identify the exact exemption, its scope and its validity period. A vague statement such as RoHS compliant except where exempted is weak unless the relevant exemption is named.

Importers should remember that a supplier declaration is not the same as a government-issued approval. In many product categories, there is no official REACH certificate issued by the EU authorities. RoHS is linked to CE marking for covered EEE, but the manufacturer, authorised representative or importer still needs a defensible conformity file rather than a decorative certificate.

How to review declarations and test reports

A useful compliance review starts with scope. The document should match the product being purchased, not only the supplier’s general catalogue. Check the model number, part number, material revision, production date, factory name if available and market covered. A declaration for EU RoHS may not cover China RoHS, UK RoHS or customer-specific restricted substance lists unless it says so clearly.

Next, check the standard or legal reference. A REACH declaration should not merely state that a product is REACH certified. It should say whether SVHCs above 0.1% are absent or present, name the Candidate List date and address relevant Annex XVII restrictions where they are material to the product. For electrical products, a RoHS declaration should refer to the ten-substance list, not the older six-substance version, unless the product is legitimately outside the later scope. See also: Customs.

Then review the depth of evidence. Laboratory reports are strongest when they identify the tested homogeneous material and the analytical method. A full finished-product screening result may help with triage, but it may not prove that every solder, coating, cable jacket or plastic insert is compliant. For REACH, testing can also be limited because the Candidate List is long and changes over time. Supplier material declarations and chemical knowledge often matter as much as lab screening.

Finally, check whether the evidence is current. A RoHS test report from several years ago may still be useful if the design, materials and suppliers have not changed. A REACH SVHC declaration without a Candidate List date is harder to rely on, because the official list changes over time. Importers should set a review cycle and require suppliers to notify them when materials, formulations, coatings, flame retardants, plasticizers or plating processes change.

Where REACH and RoHS overlap

Some substances create overlap. DEHP, BBP, DBP and DIBP are restricted under RoHS for EEE and are also important under REACH because of broader chemical control measures. Lead may appear in electrical solder, brass, pigments or stabilizers, making it relevant to RoHS, REACH restrictions or both depending on the product and use. Hexavalent chromium may be a concern in coatings and surface treatments.

However, one compliant result does not automatically prove the other. A product can pass RoHS limits and still contain a Candidate List substance that triggers REACH communication. A product can also have a REACH SVHC declaration and still fail RoHS because a homogeneous material exceeds a RoHS limit. This is why mature importers keep separate review lines in their compliance checklist even when they ask suppliers for a combined REACH and RoHS declaration.

The overlap is also important for exemptions. RoHS exemptions are specific and conditional. They do not remove obligations under REACH if a separate restriction, authorisation or communication duty applies. The European Commission’s RoHS guidance has long emphasized coherence with REACH, including the principle that one regime should not be used to weaken protection required under the other.

A practical workflow for import and export orders

1. Classify the product. Decide whether it is EEE, a non-electrical article, a substance, a mixture, packaging, spare part or accessory.
2. Map materials and components. Pay attention to plastics, cables, coatings, solders, pigments, adhesives, rubber parts, batteries and metal alloys.
3. Request supplier evidence early. Ask for dated REACH SVHC declarations, Annex XVII statements where relevant, RoHS declarations for EEE and supporting test or material data.
4. Check thresholds correctly. Use article-level thinking for REACH SVHC communication and homogeneous-material thinking for RoHS limits.
5. Document exemptions. If a RoHS exemption is used, record the exact exemption reference, technical reason and expiry or review status.
6. Review updates. Recheck REACH declarations after Candidate List updates and review RoHS files when exemptions, components or suppliers change.
7. Keep a traceable file. Store declarations, test reports, bills of materials, supplier communications and version history with the shipment or product master record.

This workflow is simple, but it prevents many common trade problems. Customs brokers, online marketplaces, distributors and EU importers may all ask for evidence on short notice. A file assembled only after goods are produced can delay shipment, force retesting or expose gaps in the supply chain.

Frequently asked questions

Does every product need both REACH and RoHS documents?

No. REACH can apply broadly to articles, substances and mixtures placed on the EU market. RoHS mainly applies to electrical and electronic equipment. A metal fastener may need REACH review but not RoHS unless it is part of covered EEE. A charger, LED lamp, control board or smart device will usually need both types of review.

Is a third-party certificate enough for REACH and RoHS compliance?

Not by itself. Third-party testing or certification can be useful evidence, especially for high-risk materials, but importers still need documents that match the product, the legal scope and the latest applicable substance list. A certificate without product identification, test scope or date has limited value.

How often should supplier declarations be renewed?

There is no universal renewal interval that fits every product. For REACH SVHC declarations, renewal after each Candidate List update is a strong practice for high-risk products. For RoHS, renewal is especially important after material changes, supplier changes, new exemptions, exemption expiry dates or design revisions.

What is the biggest mistake in combined REACH and RoHS declarations?

The biggest mistake is treating a combined declaration as a shortcut. A good combined document can save time, but it must still answer two different questions: whether the product triggers REACH chemical duties and whether each relevant homogeneous material in covered EEE meets RoHS limits.

Who is responsible if an imported product is non-compliant?

Responsibility depends on the market role and product route. In the EU, manufacturers, importers and distributors can each have duties. A non-EU exporter may not hold the same statutory role as the EU importer, but weak supplier evidence can still lead to rejected orders, recalls, blocked listings or contract claims. Commercially, both sides need accurate data before goods move.