RoHS vs. REACH: How to Determine Your Product Testing Needs

For products within EU RoHS scope, we check both RoHS and REACH. Non-electrical goods may still have REACH duties. RoHS restricts 10 substances or substance groups; REACH requirements depend on the substance, product and use.^[1][2]

At UTS, we review the product, materials and supplier records before coordinating laboratory testing. New tests should cover gaps in the evidence and any specific testing requirements.

Does Your Product Need Both?

We start with the product's function and intended use:

• Chargers, LED lamps and Bluetooth headphones: we generally assess both RoHS and REACH.
• Non-electrical bags, jewellery and furniture: we check REACH restrictions and Candidate List duties; these products normally fall outside RoHS.
• Specialist equipment: we check the product category and scope exclusions. Battery power alone does not put a product outside RoHS.^[3]

Our review includes supplied adapters, cables and accessories. We assess packaging separately against its applicable requirements. Paints and adhesives sold as mixtures need a different REACH assessment from finished articles.

RoHS vs. REACH: What Changes in the Test Plan?

Check	RoHS	REACH
Scope	The 10 restricted substances or groups in Annex II.	Relevant Annex XVII restrictions and the Candidate List assessment scope.
Basis	Each homogeneous material.	Each retained article for Candidate List duties; the basis stated in each Annex XVII entry for restrictions.
Result	Evidence against the stated substance limits and applicable exemptions.	Evidence for a specific restriction or information duty. An SVHC finding may trigger disclosure without banning the product.

We keep separate conclusions for the two assessments, even when they use some of the same laboratory results.

RoHS Limits: 0.1%, Except Cadmium at 0.01%

We assess RoHS results against the Annex II limits below. Each limit applies by weight to a homogeneous material, subject to applicable exemptions and special provisions.^[4]

Restricted substance	Limit	mg/kg
Lead (Pb)	0.1%	1,000
Mercury (Hg)	0.1%	1,000
Cadmium (Cd)	0.01%	100
Hexavalent chromium (Cr VI)	0.1%	1,000
Polybrominated biphenyls (PBB)	0.1%	1,000
Polybrominated diphenyl ethers (PBDE)	0.1%	1,000
Bis(2-ethylhexyl) phthalate (DEHP)	0.1%	1,000
Butyl benzyl phthalate (BBP)	0.1%	1,000
Dibutyl phthalate (DBP)	0.1%	1,000
Diisobutyl phthalate (DIBP)	0.1%	1,000

For mass-based measurements, 1 mg/kg = 1 ppm.

A homogeneous material has uniform composition or cannot be mechanically separated into different materials. A cable can contain several, such as its metal conductor and plastic insulation. We assess those materials separately because a whole-cable average can hide an exceedance.^[5]

If an exemption is claimed, our team checks its number, permitted use, equipment category and current status. An exemption may remain valid while a timely renewal application is pending, so an old expiry date alone does not settle the question.^[6]

REACH: Which Requirements Affect Testing?

Annex XVII restrictions

We check each relevant entry's substance, product or use, limit, calculation basis, exceptions and start date. A Candidate List screening report does not establish Annex XVII compliance.^[7]

For certain products in direct and prolonged skin contact, the nickel restriction limits nickel release. A total nickel content result cannot answer that question.^[8]

Candidate List: above 0.1% by weight

The Candidate List identifies substances of very high concern, or SVHCs. We record the list date covered by the assessment because the list changes.^[9]

Under REACH, an article is an object whose shape, surface or design determines its function more than its chemical composition. We apply the threshold to each component that retains article status, rather than averaging it across the whole assembly.^[10]

Above 0.1% by weight, Article 33 requires suppliers to give business recipients enough information for safe use, including at least the substance name. Suppliers must answer qualifying consumer requests within 45 days. These duties have no annual tonnage threshold.^[11]

A Candidate List result above 0.1% does not automatically mean the product is banned.

Article 7(2) notification

EU producers and importers must notify ECHA when both conditions apply, unless an exemption applies:

• The Candidate List substance exceeds 0.1% by weight in the relevant articles.
• That substance in those articles totals more than 1 tonne per producer or importer per year. This is the substance's weight, not the weight of the goods.

For newly listed substances, the deadline is 6 months after listing. Exemptions can apply when the substance is already registered for that use, or when human and environmental exposure can be excluded during normal or reasonably foreseeable use, including disposal. The exposure-based exemption also requires appropriate instructions to recipients.^[12]

SCIP submissions

SCIP comes from the Waste Framework Directive. EU producers, assemblers, importers and distributors placing articles on the EU market must submit information when a Candidate List substance exceeds 0.1% by weight. There is no one-tonne trigger. Retailers acting only as retailers and supplying directly and exclusively to consumers are excluded.^[13]

How We Turn Materials into a Test List

Our RoHS and REACH testing review starts with the bill of materials: the list of parts and what they are made from. We check material grades, formulations, colours, coatings, suppliers and revisions.

1. Map the parts. We link material records to product photos or drawings, including internal parts, cable insulation, coatings and supplied accessories.
2. Match the use. We record conditions that affect restrictions, such as skin contact, use by children and whether the item is electrical.
3. Check the evidence. We identify which substances and materials existing records cover and which remain unresolved.
4. Confirm the tests. Our team asks the laboratory to confirm the method, sample preparation and reporting limit for each remaining question.

The material review includes checks such as these; the final scope depends on the product and its supporting records.

Material or part	What we investigate
Solder and metal alloys	We check the alloy specification and lead evidence. A “lead-free” description without supporting composition data or a relevant report leaves an evidence gap.
Flexible plastic and cable insulation	We check plasticiser information and applicable phthalate requirements. Phthalates can occur in plastics, adhesives, coatings and cables, so the review extends beyond the main housing.[14]
Corrosion-protection coatings on metal	We check the surface treatment and whether chromium VI testing is needed. IEC 62321-7-1 addresses its presence in these coatings; a result for the underlying metal may not answer the coating question.[15]
Metal parts that touch skin	We assess the contact conditions before selecting nickel release testing. A metal part does not need the same assessment merely because it sits in the same product as a skin-contact part.
Dyed textile or leather parts	For parts within Entry 43's scope, we assess restricted aromatic amines that certain azo dyes can release. The entry covers specified textile and leather articles with direct and prolonged skin or oral contact.[16]

We also check exclusions in each restriction before ordering overlapping tests. For example, Entry 51 excludes electrical equipment within RoHS scope from its general article restriction on the four listed phthalates. That exclusion does not remove other applicable REACH duties.^[17]

What Can Your Existing Reports Cover?

We assess the relevance and reliability of supplier declarations, material data and reports before requesting new tests. Each document needs to identify what it covers.^[18][19]

We use model and material references to connect reports with the material list and change log in the product file pack.

Available evidence	What our team checks
Report covers the material and current rules	Whether the composition is unchanged and the report covers the current supplier's material.
Generic compliance declaration	Whether part numbers, substance coverage, list dates, relevant restrictions and supporting records are available.
Missing or incomplete data	Whether the supplier can fill the gap, and which tests are needed if it cannot.

We reuse a result for both RoHS and REACH only when its substance identity, sample basis, method and reporting limit support both assessments.

Can Different Models or Colours Share a Report?

We assess shared coverage by material identity, not by how similar the products look. Our team asks for a comparison showing what stays the same and what changes:

• Colour changes: we check the colourant formulation as well as the base resin. A report for one colour does not by itself establish coverage of another.
• Supplier changes: we check the exact grade and formulation. A matching trade description is not enough to establish that the material is unchanged.
• Size changes: we review whether the same materials, finishes and construction are used. Size alone does not settle chemical-test coverage.
• Accessory changes: we assess a replacement cable, adapter or strap separately when its materials are outside the existing report.

When shared coverage is justified, we record the represented models and materials. We keep changed or unsupported parts outside that grouping until their evidence is resolved.

Which Test Method Do You Need?

Our team confirms the test method with the selected laboratory:

• X-ray fluorescence (XRF) screens elements. Total chromium does not show how much is hexavalent chromium, and total bromine does not identify PBB or PBDE. High chromium or bromine readings need further investigation before they can establish a failure for those restricted substances.^[20]
• Phthalate testing needs a suitable chemical method; XRF cannot directly measure the four RoHS phthalates. IEC 62321-8 describes methods for phthalates in polymers, including gas chromatography–mass spectrometry (GC-MS).^[21]

We check whether the selected laboratory's ISO/IEC 17025 accreditation scope covers the relevant tests and materials.^[22]

Should You Send a Finished Product or Separate Materials?

We confirm this with the laboratory before dispatch. IEC 62321-2 covers sampling and mechanical preparation for electrotechnical products; the required preparation depends on the part and test.^[23]

• Finished products let the laboratory locate components and document how the submitted sample is assembled. Disassembly may consume or damage the product.
• Separate components can provide enough material when a small coating, seal or connector is difficult to recover from one finished unit. We need part numbers linking them to the product.
• Raw materials need records linking the submitted batch to production. Resin pellets alone do not represent additives or coatings applied later.

Our team requests the quantity of each part or material required for the selected methods, including any confirmation tests. A fixed number of finished units may provide plenty of housing plastic but too little of a thin coating.

We ask suppliers to keep samples separated and identify the model, part, material, colour, supplier and batch where available. We also confirm any restrictions on cutting, cleaning or other preparation before shipment.

Mixing different materials can dilute a restricted substance. We require a documented basis for any combined sample and for the conclusions drawn from it.

What Do We Check in the Report?

1. Identity: the model, sample photos and material references.
2. Coverage: the tested substances, restriction entries and Candidate List date.
3. Method: whether the test measures what the rule limits, such as content or release.
4. Results: values, units, reporting limits and how measurement uncertainty is handled.
5. Conclusion: the limit, pass/fail rule and any exemption used.

“Not detected” does not mean zero. We check whether the detection or reporting limit is low enough for the assessment.

A passing report does not replace the manufacturer's RoHS technical documentation, EU Declaration of Conformity or applicable CE marking duties.^[24]

What Happens if a Result Needs Follow-Up?

For an inconclusive screen, our team asks the laboratory which confirmation method is needed. We keep the result unresolved until the evidence supports a conclusion.

For a confirmed exceedance, we identify the affected material, represented models and applicable requirement. We then review the supplier's proposed material or process change and coordinate testing of the revised sample where needed. The new result must remain traceable to that revision.

For a Candidate List finding, we distinguish a restriction failure from a communication or notification trigger. We provide the reviewed evidence to the client; the relevant supplier or importer remains responsible for its statutory duties.

What If Something Changes Before Shipment?

If production uses a different material or component, we review whether the tested sample still represents it.

During final random inspection, we can check model IDs, accessories and labels against approved files. Those visual checks cannot replace chemical testing.

Changes to the intended use, applicable restrictions, Candidate List or RoHS exemptions also trigger a review. We coordinate retesting of affected materials when updated records cannot resolve the gap, or when the applicable rule or buyer specification requires it.