Two acronyms appear in almost every supplier email about electronics, plastics or coated goods, usually as a single line: "RoHS and REACH compliant." They restrict different things, are proved in different ways, and neither is demonstrated by the document most suppliers attach. This article is for companies importing commercial batches of electrical goods, plastic products, textiles or coated metal into the EU or into markets built on the EU model.
RoHS: what is restricted, and where
RoHS restricts hazardous substances in electrical and electronic equipment. Directive 2011/65/EU set six substances; Delegated Directive (EU) 2015/863 — commonly "RoHS 3" — added four phthalates, bringing the total to ten:
- Lead, mercury, cadmium, hexavalent chromium
- PBB and PBDE (brominated flame retardants)
- DEHP, BBP, DBP and DIBP (phthalates)
The limit is 0.1% by weight, with cadmium at 0.01%. The critical detail is what it applies to: not the product as a whole, but each homogeneous material — every individually separable material within it. A cable jacket, a solder joint, a screw plating and a plastic housing are each assessed separately. This is precisely why a single "RoHS certificate for the product" is not a meaningful document.
Why there is no RoHS certificate
RoHS compliance is self-declared by the manufacturer as part of the CE process. No authority issues a RoHS certificate. What legitimate evidence looks like:
- Test reports per material from an accredited laboratory, listing the materials tested and the results against each restricted substance
- Full material declarations from component suppliers, covering the parts you are not testing yourself
- The declaration of conformity referencing RoHS among the applicable legislation — see CE marking and how to verify a Chinese certificate
A one-page PDF headed "RoHS Certificate", issued by an unnamed body, listing "the product" with no materials and no test results, tells you only that someone owns a template.
REACH: a different mechanism entirely
Regulation (EC) No 1907/2006 (REACH) governs chemicals across all products, not just electronics. Three parts matter to an importer of finished goods:
- The SVHC Candidate List — substances of very high concern. It stood at 250 entries as of June 2025 and grows roughly twice a year, so it must be checked against the current list, never a supplier's copy from two years ago. The live list is at echa.europa.eu.
- The 0.1% communication duty. If an article contains an SVHC above 0.1% by weight, that information must be passed down the supply chain, and to consumers on request.
- Annex XVII restrictions — outright limits on specific substances in specific uses. These catch far more ordinary imports than people expect: PAHs in rubber and plastic parts that touch skin, nickel release from items in prolonged skin contact, azo dyes in textiles and leather, lead and cadmium in jewellery and coatings.
That last group is where importers of non-electronic goods get caught. A rubber grip, a watch strap, a printed textile or a painted toy can all fail REACH without a single electronic component in sight.
China RoHS is not EU RoHS
Chinese suppliers often present compliance with China's own scheme — administered through standards such as GB/T 26572 and the marking rules of SJ/T 11364 — as equivalent. It is not. The Chinese scheme differs in scope, in the marking it requires (an orange symbol with an environmental protection use period, or a green circle for compliant items), and in its exemptions.
The same applies to test reports written against GB standards: useful, sometimes technically comparable, but not evidence of compliance with the EU directive. Specify which standard you require, in writing, at the point of order — the mechanism is described in the technical spec sheet for a Chinese factory.
How compliance breaks after it is proved
- Component substitution. A cheaper connector, a different flame retardant in the same-looking housing, another plating shop — and the evidence no longer describes the product. This is one reason substitution belongs under written control, as discussed in DFM and the changes factories propose.
- Sub-suppliers changing quietly. Your factory may not know its own resin supplier changed masterbatch.
- The list moving. REACH candidates are added twice yearly; a compliant product can become a communication obligation without changing at all.
- Reports ageing. A report from three years ago, for a discontinued material, proves nothing about this year's batch.
What to request and what to test
- Test reports per homogeneous material, not per product, naming the laboratory and its accreditation number
- Full material declarations for purchased components, with substance data
- A written no-substitution clause, part of the contract with the factory
- For higher-risk categories, your own independent testing of samples pulled from production rather than sent by the supplier — which is where pre-shipment inspection and the pulling of samples matter
On testing method: XRF screening is fast, cheap and non-destructive, and it is a screening tool — good for finding heavy metals, unable to confirm phthalates or give a defensible result on its own. Laboratory analysis of specific materials is what stands up. Use XRF to triage which materials to send to a lab, not as a substitute for one.
Where this sits in the wider compliance picture
RoHS and REACH ride on top of the market-access rules rather than replacing them: in the EU they form part of the CE evidence, in Ukraine they map onto a technical regulation of their own, described in technical regulations in Ukraine and the declaration of conformity, and the full document set per market is in which documents you need to sell goods from China. Verifying that any of these documents are real is a separate skill: how to check whether a Chinese certificate is genuine.
RoHS and REACH are not documents to obtain. They are properties of the materials inside your product — which is why the only proof that survives scrutiny names the materials, the standard and the laboratory, and why a certificate naming none of those is not proof of anything.
Getting substance compliance built into the order
We write the required standards into the factory specification, review existing reports material by material against accreditation scopes, arrange independent testing on samples pulled from production, and lock component substitution down contractually. That is part of the protocol behind 3,500+ deliveries and 340+ verified suppliers over seven years — real projects in our case studies.
Start with quality inspection or document support.
