RoHS vs. REACH: Unraveling the Differences and Overlaps

In the modern world, environmental concerns have gained significant attention, prompting governments and international bodies to implement regulations aimed at safeguarding both human health and the environment. Two of the most notable regulations in this realm are RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals). Although distinct in their scopes and objectives, these regulations often intertwine due to their shared goal of promoting safer and more sustainable manufacturing practices. This article delves into the key differences and overlaps between RoHS and REACH, shedding light on their importance and implications for industries and consumers alike.

What is RoHS

The Restriction of Hazardous Substances (RoHS) directive emerged as a response to growing concerns about the adverse effects of hazardous materials in electrical and electronic equipment (EEE). Enforced within the European Union (EU) and several other countries, RoHS aims to restrict and minimize the use of 10 hazardous substances in the manufacturing of EEE as these substances have been identified as posing substantial risks to human health and the environment.

What is REACH

The Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation, is an extensive and complex system that pertains to the management of chemical substances. Originating within the EU, REACH addresses the production, import, and use of chemicals while aiming to enhance the protection of human health and the environment. REACH mandates the registration of chemical substances, evaluation of their potential risks, authorization for substances of very high concern (SVHCs), and restriction of specific substances that may pose serious threats.

Differences Between RoHS and REACH

Scope of EU REACH vs. RoHS

REACH: Broad Application Across All Products

REACH, which stands for the Registration, Evaluation, Authorization, and Restriction of Chemicals, applies to nearly all products manufactured, sold, and imported within the EU. Its broad scope ensures that a wide range of products comply with safety standards regarding chemical substances.

RoHS: Specific Focus on Electronics and Electrical Equipment

RoHS, which stands for the Restriction of Hazardous Substances, specifically targets Electronics and Electrical Equipment (EEE). This directive ensures that harmful substances within these products are restricted to protect both consumers and the environment.

Restricted Substances Under EU REACH and RoHS

REACH: Comprehensive List of Chemical Substances

REACH currently restricts 224 chemical substances, regardless of their use on their own, in mixtures, or in articles. This extensive list is managed by the European Chemicals Agency (ECHA) and aims to control substances that could potentially harm human health or the environment.

RoHS: Targeted List of Hazardous Substances in EEE

RoHS restricts the use of 10 specific substances in EEE above certain concentrations. These substances include:

• Cadmium (Cd): < 100 ppm
• Lead (Pb): < 1000 ppm
• Mercury (Hg): < 1000 ppm
• Hexavalent Chromium (Cr VI): < 1000 ppm
• Polybrominated Biphenyls (PBB): < 1000 ppm
• Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm
• Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm
• Benzyl butyl phthalate (BBP): < 1000 ppm
• Dibutyl phthalate (DBP): < 1000 ppm
• Diisobutyl phthalate (DIBP): < 1000 ppm

Exemptions to RoHS compliance exist for specific applications as listed in Annexes III & IV of the directive. These exemptions must be disclosed in RoHS compliance declarations.

Compliance Requirements for EU REACH and RoHS

REACH: Authorization and Restriction Processes

Under REACH, companies manufacturing, distributing, or importing more than one ton of substances per year must apply for authorization for Substances of Very High Concern (SVHCs). Additionally, companies must adhere to restrictions on substances listed under REACH to ensure safety.

RoHS: Self-Declaration and Technical Documentation

RoHS compliance is demonstrated through self-declaration with the CE Marking, indicating that the company has generated a technical file. This file includes detailed product information and steps taken to ensure RoHS compliance. Companies must maintain this technical file for 10 years after the product's market placement.

Enforcement Differences Between REACH and RoHS

REACH: Centralized Enforcement with Severe Penalties

As a regulation, REACH enforcement is determined at the European Commission level, with individual EU member states holding enforcement powers within existing regulations. Penalties for non-compliance can include fines and incarceration, with due diligence defenses generally inadmissible. Each case is investigated individually to determine the appropriate course of action.

RoHS: Variable Enforcement Across Member States

RoHS, being a directive, is implemented by individual EU member states through their legislative frameworks. This means enforcement policies and penalties can vary significantly between countries. Non-compliance may lead to fines, product recalls, and reputational damage, impacting multiple suppliers, manufacturers, and brands.

If you're looking to deepen your understanding of EU REACH and RoHS Compliance download the eBook for free here. It covers everything from the basics to advanced strategies for ensuring compliance and avoiding costly penalties.

Acquis REACH and RoHS Compliance Solutions

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