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Why REACH Matters for the Electronics Industry
In the global electronics industry, the EU’s REACH regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) has become a defining factor for market access—particularly for OEMs and component manufacturers placing products on the EU market.
If you manufacture or import electronic goods into the EU, you are responsible for understanding which substances are present in your products, including substances introduced upstream by suppliers.
Key Obligations Under REACH for Electronics
- Substance Identification in Articles
Electronic components and finished electronics are commonly classified as “articles” under REACH. For each article, companies must determine whether any Substances of Very High Concern (SVHCs) are present above 0.1% w/w, assessed per article, not averaged across the finished product.
- Article 33 Communication Requirements
Under Article 33 of REACH, if an SVHC is present above 0.1% w/w, you must:
- Inform downstream customers and professional recipients
- Provide sufficient information to allow safe use of the article
- Respond to consumer SVHC requests within 45 days
Article 33 creates a supply-chain communication obligation. It does not require database submissions.
- SCIP Database Obligations (Waste Framework Directive)
Separate from REACH, companies placing articles containing Candidate List SVHCs above 0.1% w/w on the EU market must submit required information to the ECHA SCIP database under the EU Waste Framework Directive.
In practice, electronics manufacturers must comply with both:
- REACH Article 33 communication duties, and
- SCIP database submission requirements administered by European Chemicals Agency.
Full Material Disclosure (FMD) vs REACH Compliance
REACH requires sufficient substance-level data to identify SVHCs, but it does not mandate full composition disclosure.
Full Material Disclosure (FMD) goes further by mapping all materials and substances down to CAS level across the product structure. While not legally required, FMD significantly accelerates compliance workflows for:
- SCIP submissions
- SVHC screening
- Customer and OEM substance declarations
Common REACH Risk Areas in Electronics
In practice, REACH exposure in electronics is rarely evenly distributed across a product.
Compliance risk tends to concentrate in specific materials and component categories where regulated substances are commonly used for performance, durability, or processing reasons.
- Circuit Boards: Brominated flame retardants and certain phthalates used in resins and laminates
- Solder and Contacts: Lead, cadmium, and hexavalent chromium compounds (often overlapping with RoHS risk)
- Cables and Plastics: DEHP, BBP, and other restricted phthalates commonly used as plasticizers
How to Prepare for REACH Compliance
- Map Your Supply Chain: Identify every component, material, and supplier
- Conduct SVHC Screening: Use BOM and supplier data to assess Candidate List exposure
- Adopt FMD Practices: Even if not required, FMD data enables scalable compliance
- Automate SCIP Reporting: Reduce errors, rework, and enforcement exposure
Why It Matters: Enforcement Trends
REACH enforcement is becoming more coordinated and more data-driven. EU member states, working through European Chemicals Agency, conduct joint REACH Enforcement Projects (REF) that increasingly target electronics and complex articles.
Failure to comply can result in:
- Product recalls or withdrawals
- Market access bans
- Administrative fines and penalties
Ready to Simplify REACH for Your Electronics?
Acquis supports electronics manufacturers with: