RoHS & REACH Compliance
Before your product enters the EU, every material in it must be documented. RoHS and REACH are the two regulations that enforce chemical safety — and they apply to more products than most founders realize.
RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) are EU regulations that govern the chemical composition of products sold in the European market. Together they cover nearly every consumer product — not just electronics — and require documented evidence that your materials are free of restricted substances above specified thresholds.
For hardware founders, RoHS and REACH are often confused with safety certifications like CE. They are not the same. CE covers electromagnetic compatibility and product safety. RoHS and REACH cover what your product is made of — the lead in your solder, the phthalates in your plastic, the cadmium in your plating. You can pass CE and still fail REACH.
RoHS (Directive 2011/65/EU, often called RoHS 2 or RoHS 3) restricts six substances — lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE — plus four phthalates (DEHP, BBP, DBP, DIBP) added in RoHS 3. The threshold is 0.1% by weight in homogeneous materials (0.01% for cadmium). A "homogeneous material" means you cannot mix compliant and non-compliant materials and average them together — each individual material in each component must pass. RoHS applies to electrical and electronic equipment specifically, but the definition is broad: anything with a circuit board, a motor, a heating element, or a battery counts.
REACH (Regulation EC 1907/2006) is broader. It applies to all products — not just electronics — and regulates substances of very high concern (SVHCs), which currently number over 240 and grow every year. REACH requires you to know and document whether any SVHC is present above 0.1% in any article you sell. For some substances, you need explicit authorization. For others, you must report to the European Chemicals Agency (ECHA) and provide information to customers on request.
Testing is done through third-party labs (SGS, Intertek, Bureau Veritas) using XRF screening and chemical analysis. A typical RoHS test costs $200–$500 per material. A full REACH SVHC screen costs $500–$1,500 depending on material count. Testing must cover every homogeneous material in your product, not just the final assembly. A product with five different plastic resins, three metal alloys, and two coatings means at least ten separate material tests.
RoHS/REACH failures
Assuming your factory's "RoHS compliant" claim without documentation
Many factories claim RoHS compliance but cannot produce test reports. Without lab documentation, your product is not compliant — and you are liable for any violations.
Missing REACH because you only tested for RoHS
RoHS covers 10 substances. REACH covers 240+. A product that passes RoHS can still fail REACH on an SVHC. Test for both.
Testing the final product instead of each material
RoHS limits apply per homogeneous material, not to the whole product. A compliant average can hide a non-compliant material. Test at the material level.
Forgetting about packaging
EU Packaging Directive (94/62/EC) limits heavy metals in packaging. Your product may be clean, but cadmium in the box printing ink fails compliance.
What founders should remember
RoHS applies to any product with electronics sold in the EU
If your product has a PCB, a battery, a motor, or a heating element, you need RoHS compliance documentation. This is not optional.
REACH applies to all products, not just electronics
Clothing, furniture, toys, kitchenware — if you sell physical goods in the EU, REACH applies. Plan for SVHC screening regardless of product category.
Lab test reports are your evidence, not your factory's word
Accept only lab reports from ISO 17025-accredited labs with your product name and batch reference on them. Anything less is not compliance documentation.