The REACH Regulation and the RoHS Directive are the two primary legislative frameworks governing chemical safety in the European Union. While they share the overarching goal of protecting human health and the environment, they operate differently, apply to different scopes, and impose distinct obligations on businesses.
Core Definitions and Scope
The fundamental difference lies in their scope of application:
- REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals): A broad, horizontal regulation that applies to almost all chemical substances manufactured or imported into the EU, whether on their own, in mixtures, or in articles (products). It affects virtually every industry.
- RoHS (Restriction of Hazardous Substances): A vertical, product-specific directive that applies exclusively to Electrical and Electronic Equipment (EEE). It restricts a specific, short list of hazardous substances from being used in electronics.
Substance Restrictions
The approach to restricting substances differs significantly:
- RoHS Restrictions: RoHS restricts exactly 10 specific substances (Lead, Mercury, Cadmium, Hexavalent chromium, PBB, PBDE, and four phthalates) at specific maximum concentration values (usually 0.1% by weight in homogeneous materials). If an EEE product contains these above the limit without an exemption, it cannot be sold in the EU.
- REACH Restrictions and Authorisations: REACH manages thousands of substances through multiple lists. The Candidate List identifies Substances of Very High Concern (SVHCs) which trigger communication duties. The Authorisation List (Annex XIV) bans substances unless specific permission is granted. The Restriction List (Annex XVII) limits or bans substances in specific applications.
Compliance Mechanisms
How companies prove compliance is entirely different under the two frameworks:
- RoHS Compliance: RoHS is a CE marking directive. Manufacturers must ensure the product meets the substance limits, compile technical documentation, issue an EU Declaration of Conformity, and affix the CE mark to the product.
- REACH Compliance: REACH is based on the principle of "No data, no market." It requires manufacturers and importers to register substances with the European Chemicals Agency (ECHA) by submitting extensive technical dossiers. There is no CE mark for REACH.
Overlap and Interaction
For manufacturers of electrical and electronic equipment, both regulations apply simultaneously. An electronic device must comply with the RoHS restrictions for the 10 specific substances AND comply with REACH requirements for all other chemicals it contains (e.g., SVHC communication duties, Annex XVII restrictions).
When a substance is regulated by both, the strictest requirement generally applies. The EU actively works to align the two frameworks to avoid contradictory regulations, often using REACH methodologies to evaluate new substances for potential inclusion in RoHS.
Summary Comparison
| Feature | REACH Regulation | RoHS Directive |
|---|---|---|
| Scope | All chemical substances (with few exemptions) | Electrical and Electronic Equipment (EEE) only |
| Number of Substances | Thousands (across Candidate, Authorisation, and Restriction lists) | Exactly 10 specific substances |
| Primary Mechanism | Registration of data; Authorisation for use; Restrictions | Strict concentration limits (bans) with specific exemptions |
| CE Marking | Not applicable | Mandatory requirement |
| Administered By | European Chemicals Agency (ECHA) | National authorities of Member States |