REACH vs RoHS: What Each Rule Means for Chemical Products

REACH covers almost every chemical substance, mixture and article on the EU market; RoHS covers only restricted substances in electrical and electronic equipment. A grease, adhesive or coating sold on its own falls under REACH, not RoHS. Once it is built into equipment, RoHS limits apply to it as one material of that equipment.

• RoHS Annex II restricts 10 substances to 0.1% by weight in each homogeneous material, and cadmium to 0.01% (Directive 2011/65/EU, Annex II, as amended by Delegated Directive 2015/863).

• REACH requires a manufacturer or importer of a substance, on its own or in mixtures, to register it at one tonne or more per year (Regulation 1907/2006, Article 6).

• A supplier of an article containing a Candidate List substance above 0.1% weight by weight (w/w) must give the recipient at least the substance name, and must answer a consumer's request free of charge within 45 days (Regulation 1907/2006, Article 33).

• For a product made of several articles, the 0.1% w/w threshold applies to each article, not to the whole product (CJEU, Case C-106/14, 2015).

This comparison covers the EU texts as consolidated on 22 June 2026 (REACH) and 1 July 2026 (RoHS). It does not cover UK REACH, China RoHS, K-REACH or US TSCA, which keep their own lists and thresholds, or the CLP labeling rules for mixtures.

How do REACH and RoHS differ?

REACH and RoHS differ in what they cover, what triggers them and who proves compliance. REACH, the Registration, Evaluation, Authorisation and Restriction of Chemicals regulation, applies to the manufacture, placing on the market and use of substances on their own, in mixtures or in articles (Regulation 1907/2006, Article 1). RoHS, the Restriction of Hazardous Substances directive, lays down rules restricting hazardous substances in electrical and electronic equipment (EEE) (Directive 2011/65/EU, Article 1). Its list holds 10 substances: lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers and four phthalates, DEHP, BBP, DBP and DIBP (European Commission RoHS page, accessed 2026). The European Commission's guidance puts it plainly: "RoHS and REACH are two different acts with different scopes and objectives." (European Commission RoHS 2 FAQ, 2012).

The table below shows which rule sets each duty for a grease, adhesive or coating used in electronics.

The row that changes the most work is the threshold basis: RoHS applies 0.1% by weight to each homogeneous material, while REACH applies 0.1% w/w to each article (Directive 2011/65/EU, Annex II; CJEU, Case C-106/14, 2015).

Does RoHS apply to greases, adhesives and coatings used in electronics?

RoHS applies to greases, adhesives and coatings only as part of electrical and electronic equipment placed on the EU market; sold on their own, they are not EEE. The directive defines EEE as equipment that depends on electric currents or electromagnetic fields to work properly, designed for a voltage rating not exceeding 1 000 volts AC and 1 500 volts DC (Directive 2011/65/EU, Article 3). A grease in a drum needs no current to do its job, so it is not equipment. The Commission guidance confirms that consumables that do not meet the EEE definition, such as soap powder, are not in scope (European Commission RoHS 2 FAQ, 2012).

Inside a finished device, the picture changes. The Commission states that EEE can only meet the substance requirements "if all its components and parts meet the substance restriction requirements of RoHS 2" (European Commission RoHS 2 FAQ, 2012). A cured adhesive bead, a conformal coating or a contact grease then counts as a homogeneous material, which the directive defines as one material of uniform composition throughout, or a combination that cannot be separated mechanically (Directive 2011/65/EU, Article 3). The Annex II maximum concentration values are applied to each homogeneous material individually (European Commission RoHS 2 FAQ, 2012), unless an Annex III or IV exemption applies. If two coating layers can be separated by physical methods, they are two homogeneous materials (European Commission RoHS 2 FAQ, 2012).

When does REACH matter more for a chemical product?

REACH matters more for any grease, adhesive or coating sold as a product, because REACH, not RoHS, sets the duties for the mixture itself. Any manufacturer or importer of a substance, on its own or in mixtures, in quantities of one tonne or more per year must register it with the European Chemicals Agency (ECHA) (Regulation 1907/2006, Article 6). The supplier of a mixture classified as hazardous under the CLP Regulation must provide a safety data sheet (SDS) (Regulation 1907/2006, Article 31).

REACH also restricts and authorizes substances in ways that reach the product before it ever meets a circuit board. A substance in Annex XVII may not be manufactured, placed on the market or used unless it complies with the conditions of that restriction, whether on its own, in a mixture or in an article (Regulation 1907/2006, Article 67). A substance in Annex XIV may not be placed on the market or used without an authorisation or an exemption for that use (Regulation 1907/2006, Article 56).

REACH also covers the many machines RoHS leaves out. RoHS does not apply to large-scale stationary industrial tools, large-scale fixed installations or means of transport for persons or goods, except electric two-wheel vehicles that are not type-approved, among other exclusions (Directive 2011/65/EU, Article 2). A lubricant or sealant used in those machines still answers to REACH, because REACH applies on its own scope (Regulation 1907/2006, Article 1) and RoHS applies "without prejudice to" REACH (Directive 2011/65/EU, Article 2).

Can a product be RoHS compliant but not REACH compliant?

Yes, a product can be RoHS compliant and still break REACH, because REACH covers substances RoHS does not list and measures them on a different basis. A device can keep all 10 Annex II substances below their limits and still contain a substance of very high concern (SVHC) from the Candidate List above 0.1% w/w in one of its articles. In that case its supplier must give the recipient enough information to allow safe use, as a minimum the name of the substance (Regulation 1907/2006, Article 33). A RoHS declaration says nothing about that duty.

The basis of the threshold widens the gap. For a product made of several articles, the Court of Justice of the European Union (CJEU) ruled that the 0.1% w/w threshold is checked for each article, not for the assembled product (CJEU, Case C-106/14, 2015). RoHS checks each homogeneous material instead (Directive 2011/65/EU, Annex II), so the same device is measured twice, on two different bases.

The reverse also holds. A grease with a complete REACH SDS can still make a finished device fail RoHS if it carries a restricted substance above the Annex II limit, because REACH paperwork for a mixture does not test that limit. The Commission sums up the relationship: "RoHS 2 does not affect the application of REACH, and vice-versa, with regard to the restriction of substances in EEE" (European Commission RoHS 2 FAQ, 2012).

Which documents prove REACH and RoHS compliance?

No single certificate proves both REACH and RoHS compliance: RoHS is shown by the equipment maker's technical documentation and EU declaration of conformity, and REACH by the SDS for a mixture and Article 33 information for an article. Under RoHS, the manufacturer draws up technical documentation, carries out internal production control, draws up the EU declaration of conformity and affixes the CE marking, then keeps the documentation and declaration for 10 years after the equipment is placed on the market (Directive 2011/65/EU, Article 7). By drawing up the declaration, the manufacturer assumes responsibility for compliance (Directive 2011/65/EU, Article 13).

The Commission published the reference of EN IEC 63000:2018 as the harmonised standard for this technical documentation, covering materials, components and equipment, and it replaced EN 50581:2012 (Implementing Decision 2020/659). A chemical supplier's material declaration feeds that file; RoHS puts no declaration duty on the supplier of a grease sold on its own.

Under REACH, the SDS travels with a hazardous mixture (Regulation 1907/2006, Article 31). An unclassified mixture still needs an SDS on request when it contains a Candidate List substance at 0.1% by weight or more, among other cases (Regulation 1907/2006, Article 31(3)). For articles, Article 33 information goes to the recipient, and since 5 January 2021 article suppliers also send that information to ECHA (Directive 2008/98/EC, Article 9). The file is not a shield: if enforcement analysis finds a violation, the manufacturer bears full responsibility even after assessing the equipment according to the standard (European Commission RoHS 2 FAQ, 2012).

What drives the REACH and RoHS compliance effort over a product's life?

The REACH and RoHS compliance effort over a product's life is driven by changes: changes to the regulated lists, to formulations and suppliers, and to the number of materials in each device. The one-time declaration is the smaller part.

List changes come first. ECHA must publish and update the Candidate List on its website without delay after each decision to include a substance (Regulation 1907/2006, Article 59), so an article that met Article 33 at launch can trigger a new information duty later. The RoHS Annex II list is reviewed periodically and must stay coherent with REACH Annexes XIV and XVII (Directive 2011/65/EU, Article 6).

Formulation and supplier changes come second. RoHS requires procedures so that series production stays in conformity, and changes in product design or characteristics must be taken into account (Directive 2011/65/EU, Article 7). A reformulated grease or a new coating source therefore means new evidence for every device that uses it.

Material count comes third. Every adhesive, coating, grease and solder is a separate homogeneous material under RoHS, while REACH Article 33 checks Candidate List content against 0.1% w/w of each article (Regulation 1907/2006, Article 33; CJEU, Case C-106/14, 2015), so a device with more chemical materials carries more evidence to keep current. Record keeping comes last: RoHS files stay available for 10 years (Directive 2011/65/EU, Article 7). Matching supplier SDSs, certificates and declarations against both rules for each device is the kind of case Lubinpla structures into one cited document for your review.

FAQ

Do REACH SVHCs and RoHS restricted substances overlap?

Yes, partly. The four phthalates that Delegated Directive 2015/863 added to RoHS Annex II from 22 July 2019 (22 July 2021 for medical devices and monitoring and control instruments), DEHP, BBP, DBP and DIBP, are substances of very high concern under REACH (Delegated Directive 2015/863). Any review of the RoHS list must stay coherent with REACH and take account of REACH Annexes XIV and XVII (Directive 2011/65/EU, Article 6).

Which limit applies when REACH and RoHS both restrict a substance?

The Commission guidance says that when overlaps occur, the strongest restriction, meaning the lowest maximum concentration, should be applied (European Commission RoHS 2 FAQ, 2012).

Do RoHS limits apply to chemicals used only during production?

No. The Commission guidance states that RoHS restrictions apply only to finished EEE, so a restricted substance may be used in the production process as long as other rules allow it and the finished equipment does not contain it above the maximum concentration values (European Commission RoHS 2 FAQ, 2012). REACH still applies to that process chemical.

Working a case like this? Lubinpla works it from your own documents and site history, step by step with your approval. Free to start, no card.

Lubinpla does not sell chemical products and names no brands in recommendations. Our reviewer also leads a specialty chemicals distribution company.

Sources checked 2026-10-13.

Sources

1. European Parliament and Council. Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (recast), consolidated text. 1 July 2026. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02011L0065-20260701

2. European Commission. Commission Delegated Directive (EU) 2015/863 amending Annex II to Directive 2011/65/EU as regards the list of restricted substances. 2015. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015L0863

3. European Parliament and Council. Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), consolidated text. 22 June 2026. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20260622

4. European Parliament and Council. Directive 2008/98/EC on waste, consolidated text. 16 October 2025. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0098-20251016

5. European Commission. Commission Implementing Decision (EU) 2020/659 on the harmonised standard for technical documentation drafted in support of Directive 2011/65/EU. 2020. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020D0659

6. Court of Justice of the European Union. Judgment in Case C-106/14, FCD and FMB. 10 September 2015. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62014CJ0106

7. European Commission. RoHS 2 FAQ. 12 December 2012. https://environment.ec.europa.eu/document/download/e34bb7d9-50dd-4ae2-91a2-a45cdc1692fd_en?filename=FAQ%20key%20guidance%20document%20-%20RoHS.pdf

8. European Commission. Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS). Accessed 2026-10-13. https://environment.ec.europa.eu/topics/waste-and-recycling/rohs-directive_en

Written by the Lubinpla team from the sources listed and checked against them before publication.