RoHS, REACH and WEEE
Distinguish substance restrictions, SVHC information duties, and end-of-life obligations for electrical and electronic equipment placed on the EU market.
Written and technically reviewed byElectroDesignForge Engineering Team
View the editorial process📖 In brief
For electrical and electronic equipment placed on the EU market, RoHS, REACH, and WEEE are complementary. RoHS restricts specified substances in equipment; REACH governs chemicals and information on substances of very high concern (SVHCs); and WEEE addresses the collection and treatment of equipment at end of life. A “RoHS compliant” statement alone therefore does not demonstrate REACH or WEEE compliance.
Three frameworks, three questions
| Framework | Main question | Practical consequence for an electronics manufacturer |
|---|---|---|
| RoHS | Are restricted substances present in EEE above the permitted limits? | Check homogeneous-material composition and any exemptions. |
| REACH | Which chemicals are present, and what information must flow through the supply chain? | Obtain material declarations, monitor the SVHC Candidate List, and communicate the required information. |
| WEEE | How will equipment be collected, financed, and treated once it becomes waste? | Establish the producer role, national registration, marking, and applicable take-back route. |
These are EU frameworks, but several operating duties — especially WEEE registration, producer-responsibility schemes, placing-on-the-market reporting, and deadlines — depend on national implementation. This reference supports engineering work; it is not legal advice for a particular country.
RoHS: restricting specified substances in equipment
RoHS Directive 2011/65/EU covers electrical and electronic equipment (EEE) placed on the EU market. It restricts ten substances in homogeneous materials: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates (DEHP, BBP, DBP, and DIBP).
The usual maximum concentrations are 0.1% by weight in each homogeneous material, except cadmium, which is limited to 0.01%. A homogeneous material cannot be mechanically separated into different materials: an enclosure plastic, wire insulation, solder, and plating must therefore be considered separately.
Items that require checking
- Product scope: equipment categories, accessories, and spare parts do not always fall under identical rules.
- Exemptions: they are specific, time-limited, and can change. Never assume an exemption remains available for another product, category, or date.
- Supplier declarations: useful evidence, but they must match the exact part number, revision, and bill of materials.
- Processes: solder, surface finishes, pigments, cables, batteries, adapters, and subassemblies are frequent sources of incomplete data.
RoHS is not a single finished-product test. A robust process combines a controlled bill of materials, material evidence, an exemption review, and traceable component changes.
REACH: tracking substances and their information
REACH is the EU chemicals regulation. It reaches far beyond electronics and can apply to substances, mixtures, and articles. Under REACH, an article is an object whose shape, surface, or design determines its function to a greater degree than its chemical composition. A circuit board, cable, or enclosure can therefore be an article.
ECHA’s Candidate List identifies substances of very high concern (SVHCs). It is updated over time, so a material declaration should state the list version and date against which it was assessed.
SVHC threshold and communication
When an article contains a Candidate List substance above 0.1% weight by weight, the supplier must provide professional recipients with information sufficient for safe use, including at least the substance name. A consumer may request this information; the supplier must answer free of charge within 45 days.
For complex objects, the threshold is assessed for each constituent article, not simply against the mass of the assembled product. A small component’s mass in a complete device therefore does not automatically remove an obligation related to a connector, cable, or subassembly.
SCIP: information for the waste stage
The SCIP database is linked to the Waste Framework Directive. Companies supplying articles on the EU market that contain a Candidate List SVHC above 0.1% weight by weight generally have to submit the required information to ECHA. The notification and implementation details depend on the party’s role in the supply chain and must be confirmed for the specific case.
WEEE: planning for end of life
Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) is intended to support separate collection and appropriate treatment of EEE at end of life. It complements RoHS: reducing hazardous substances can help treatment, but it does not replace waste-management duties.
The crossed-out wheeled-bin symbol indicates that equipment must not be disposed of with unsorted municipal waste. It must be applied under the conditions relevant to the product; a bar below the symbol can identify placement on the market after a reference date set by the Directive.
Questions to resolve before placing a product on the market
- In each target country, who is legally the producer: local manufacturer, importer, distance seller, or authorised representative?
- Which national registration and periodic quantity reports are required?
- Which take-back or producer-responsibility scheme funds collection and treatment?
- Do marking, user information, and technical documentation match the country and equipment category?
- Are batteries, packaging, and other regulated streams handled separately where applicable?
Building an actionable compliance file
An efficient approach begins before the bill of materials is frozen.
- Define markets and company roles. Distinguish manufacturer, importer, distributor, and authorised representative; their duties are not interchangeable.
- Structure the bill of materials. Retain part numbers, revisions, manufacturers, critical materials, and subassemblies; attach declarations to the parts actually purchased.
- Collect evidence. Request dated RoHS and REACH declarations, SVHC information, claimed exemptions, and, where risk warrants it, focused analytical reports.
- Assess every change. A changed component, supplier, or finish can change RoHS, REACH, and SCIP status without changing electrical function.
- Prepare external information. Markings, the user manual, the EU declaration of conformity, REACH responses, and WEEE registrations must all match the product actually placed on the market.
- Record the decision. Keep the scope, regulatory version, assumptions, evidence, and validator so that a customer or authority query can be answered.
Frequent errors
| Error | Why it is a problem | Better practice |
|---|---|---|
| Treating “RoHS” as a complete environmental-compliance statement | REACH and WEEE cover different duties. | Maintain three separate, linked checklists in the product file. |
| Calculating RoHS thresholds from whole-product mass | RoHS considers homogeneous material. | Identify plating, solder, polymers, and metals separately. |
| Treating a REACH declaration as permanent | The Candidate List changes. | Record the date and list version, then schedule a review. |
| Omitting cables, adapters, or packaging | They can be articles or separate regulated streams. | Extend scope to everything supplied to the customer. |
| Applying the crossed-out-bin symbol without a take-back arrangement | WEEE marking does not replace registration or financing of collection. | Confirm country-level duties before every launch. |
EU launch checklist
- Is the product EEE within the scope of RoHS and/or WEEE in every sales country?
- Does the complete bill of materials have RoHS evidence tied to the correct part numbers and revisions?
- Are exemptions documented, valid for the product, and monitored through their expiry?
- Has the REACH Candidate List been checked at a known date, article by article?
- Are REACH information and, where required, SCIP data prepared for SVHCs above 0.1% weight by weight?
- Have the WEEE producer role, registration, producer-responsibility scheme, and marking been confirmed for every country?
- Do the technical file, EU declaration of conformity, manual, and customer communication describe the same product revision?
Related references
- Component temperature grades — select parts compatible with the intended environment and lifecycle.
- MTBF versus service life — separate reliability, repairability, and end-of-life requirements.