Environmental Assessment

Comparison between RoHS and REACH Compliance

RoHS

With many things in common, the European Union’s (EU) Restriction of Hazardous Substances (RoHS) and Registration, Evaluation. Authorization and Restriction of Chemicals (REACH) regulate the use of certain chemicals in many products. However, RoHS and REACH compliance differ in many aspects.

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RoHS and REACH: What are the Similarities and Differences?

Please find the main distinctions in the table below:


RoHS

REACH

Market

The European Union (EU), and other markets (the UK, Turkey, China, etc.)

Same (mainly the EU on articles and other jursidictions on chemicals)

Scope

Electrical and Electronic Equipment (EEE) parts manufactured, distributed, and imported within the EU.

All parts and products manufactured, sold, and imported within the EU.

Who Enforces the Regulation?

The European Parliament and the Council of the European Union

European Chemicals Agency (ECHA)

Type

Restrictive Directive

Both declarative and restrictive Regulation

Controlled Substances

  • Lead (Pb) and lead compounds
  • Cadmium (Cd) and cadmium compounds
  • Mercury (Hg) and mercury compounds
  • Hexavalent chromium (Cr 6+) and hexavalent chromium compounds
  • Polybrominated biphenyls (PBBs)
  • Polybrominated diphenyl ethers (PBDEs)
  • Butyl benzyl phthalate (BBP)
  • Di-n-butyl phthalate (DBP)
  • Di(2-ethylhexyl) phthalate (DEHP)
  • Diisobutyl phthalate (DIBP)

Declarable chemicals found in the Candidate List of substances of very high concern list (SVHC List). It is updated every six months

 

Restrictions found in Annex XVII

Threshold

At the Homogenous Material Level:

 

  • < 0.01% or 100 ppm for cadmium
  • < 0.1% or 1000 ppm for remaining substances

0.1% of any of the SVHCs at the Article Level (component)

Penalties

EU Member States set the rules on penalties. There may be an inspection at the borders or by surveillance agencies. These can include:

  • Withdrawal of the product from the EU market.
  • May have to issue a recall notice.
  • Administrative penalties.
  • Criminal penalties.
  • Some member states may also choose not to enforce a penalty.

Same. All EU Member States indicate a penalty for an infringement. Penalties depend on the country. 

Notes

RoHS does permit certain exemptions under specific applications when disclosed. 

The SCIP database, an open-source database, is used to declare any SVHC above the threshold.

What does a Homogenous Material or an Article Level mean for RoHS and REACH?

According to the RoHS directive, a homogenous material has a uniform composition. Namely, it cannot be destroyed or divided into different materials with abrasive processes. For example, grinding, cutting, and crushing would not separate the material. Indeed, it would maintain its uniformity. Therefore, for RoHS, every material in a product needs to fall below the 0.1% threshold (or 0.01% for cadmium). 

Whereas for REACH, an article would be any individual component. For example, a resistor would be considered an article. Thus, any SVHC above the 0.1% (w/w) threshold needs to be declared. Understanding this concept is a step towards RoHS and REACH compliance.

RoHS and REACH Compliance

How to Ensure RoHS and REACH Compliance?

Using vigorous environmental compliance procedures, gather and record product and supplier documentation. Moreover, your methodologies should clarify how you verify your product for RoHS and REACH compliance. 

Thus, you may collect the following from upstream suppliers:

  • Certificates of Conformity (CoCs)
  • Safety Data Sheets (SDSs)
  • Full Material Disclosures (FMDs)
  • Drawing Sheets
  • The free Enviropass EPEC form
Enviropass resources

Thus, with this documentation, you can build your technical file. It can include:

  • A complete Bill of Materials (BOM) including consumables.
  • Your supplier documentation.
  • A record of the RoHS and REACH compliance status of every part.

Additionally, if you have missing information, you can perform:

  • A risk assessment to verify the odds and the risk level of having substances above the thresholds.
  • Lab sample testing 
  • A change in a particular part that has RoHS and REACH compliance.

Need help with RoHS and REACH compliance? Want to reduce your risks? Contact Enviropass for a free consultation.