RoHS and REACH explained

RoHS and REACH are often mentioned in the same breath, and supplier declarations frequently cover both on one page. They are, however, different pieces of EU law with different scopes, different thresholds and different obligations. RoHS is a product rule: certain substances may not be present above set limits in electrical and electronic equipment. REACH is a chemicals regulation: for finished articles such as connectors and cables, its most visible effect is a duty to tell customers when a substance of very high concern is present above 0.1 % by weight.

This article sets out what each regulation requires, how the thresholds are applied, how exemptions work and expire, what the SCIP database is, and how to read the declarations that component suppliers provide. It describes the legal framework in general terms and is not legal advice; classification and compliance decisions remain the responsibility of the company placing the product on the market, supported by its own compliance function.

Two regulations, two different logics

A component can therefore be RoHS compliant and still trigger REACH obligations. The most common example in connectors is lead in copper alloys: it may be permitted under a RoHS exemption, but lead is also on the REACH Candidate List, so a contact containing more than 0.1 % lead by weight must be communicated under REACH regardless of the RoHS status.

RoHS: scope, substances and thresholds

Directive 2011/65/EU (often called RoHS 2) requires that EEE placed on the EU market, including cables and spare parts for its repair, reuse, updating of functionality or upgrading of capacity, does not contain the substances in Annex II above the maximum concentration values. The directive defines cables in scope as cables with a rated voltage below 250 V that connect EEE to the electrical outlet or connect two or more items of EEE to each other. Since 22 July 2019 the scope has been open: all EEE is covered unless specifically excluded.

The threshold applies per homogeneous material — a material of uniform composition that cannot be mechanically separated into different materials. For a connector this means the plating, the base metal of the contact, the insulator, the seal, the cable jacket and the conductor are each assessed on their own. A lead-containing plating layer cannot be "diluted" by the weight of the whole connector.

Who is responsible, and where CE marking fits

The obligations in the directive fall on the manufacturer of the EEE — the company that makes or has made the equipment and markets it under its own name — and on importers and distributors in their respective roles. The manufacturer draws up technical documentation, carries out internal production control, issues an EU declaration of conformity, affixes the CE marking to the finished product and keeps the documentation for ten years after placing on the market. The harmonised standard EN IEC 63000 describes the technical documentation, which in practice rests largely on supplier declarations, material data and, where risk warrants it, analytical testing.

A loose connector or contact intended for building into equipment is a component rather than finished EEE, and does not itself carry a CE marking for RoHS. The equipment manufacturer still needs evidence that every component is compliant, which is why component suppliers issue RoHS declarations. Cables within the directive's cable definition are in scope in their own right.

RoHS exemptions and how they expire

Where substitution is not yet technically or scientifically practicable, or where the alternatives would be worse overall, specific applications are exempted. Annex III lists exemptions for all EEE; Annex IV lists additional exemptions specific to medical devices and monitoring and control instruments. Exemptions relevant to connectors and cable assemblies include, for example, lead as an alloying element in steel, aluminium and copper alloys — exemption 6(c) covers copper alloy containing up to 4 % lead by weight, used for machinable brass and bronze contacts — and lead in high-melting-temperature solders and in certain glass and ceramic components.

• Validity: an exemption is granted for up to five years, or up to seven years for medical devices and monitoring and control instruments (categories 8 and 9), unless a shorter period is set.
• Renewal: an application for renewal must be submitted no later than 18 months before expiry. The existing exemption remains valid until the Commission has decided on the application.
• Expiry after refusal: if renewal is rejected or the exemption is revoked, it expires at the earliest 12 months and at the latest 18 months after the date of that decision.
• Narrowing: renewals frequently come with narrower wording, lower limits or different end dates for different equipment categories.

REACH: SVHCs, the Candidate List and Article 33

REACH, Regulation (EC) No 1907/2006, covers the registration, evaluation, authorisation and restriction of chemicals. Substances meeting the criteria of Article 57 — for example carcinogenic, mutagenic or toxic for reproduction, persistent and bioaccumulative, or of equivalent concern — can be identified as substances of very high concern and placed on the Candidate List maintained by the European Chemicals Agency (ECHA). The list is extended regularly, usually twice a year, and as of early 2026 contained more than 250 entries. Many substances relevant to electrotechnical products are on it, including lead, several phthalates and some flame retardants.

For articles — objects whose shape, surface or design determines their function more than their chemical composition, which includes connectors, contacts, cables and assemblies — the key obligations are:

• Article 33(1): any supplier of an article containing a Candidate List substance above 0.1 % weight by weight must provide the recipient with sufficient information, available to the supplier, to allow safe use of the article — as a minimum, the name of the substance. This applies automatically, without a request.
• Article 33(2): on request from a consumer, the same information must be provided free of charge within 45 days.
• Article 7(2): producers and importers of articles must notify ECHA when the substance is present above 0.1 % by weight and above one tonne per year in their articles in total, no later than six months after the substance was added to the Candidate List, unless an exemption applies.

Unlike the RoHS threshold, the REACH 0.1 % is calculated per article, not per homogeneous material. The Court of Justice of the EU confirmed in case C-106/14 (10 September 2015) that an article remains an article when it is assembled into a more complex product. The threshold therefore applies to each component article — a contact, a seal, a cable — and not to the finished assembly as a whole.

Being on the Candidate List does not by itself prohibit a substance. Prohibitions and conditions come through the separate restriction procedure (Annex XVII) and the authorisation procedure (Annex XIV), which may follow for some Candidate List substances.

The SCIP database

Since 5 January 2021, the Waste Framework Directive (2008/98/EC, as amended by Directive (EU) 2018/851, Article 9(1)(i)) requires any supplier of an article to submit the information it must provide under REACH Article 33(1) to ECHA as well. ECHA collects these notifications in the SCIP database (Substances of Concern In articles as such or in complex objects (Products)), which is accessible to waste treatment operators and to consumers. The aim is better-informed recycling and substitution.

The duty applies to EU producers, assemblers, importers and distributors that place such articles on the market — retailers and others that supply articles directly and exclusively to consumers are not required to notify; the directive is implemented through national legislation, so practical details can differ between Member States. ECHA provides mechanisms for downstream suppliers to refer to notifications already made upstream instead of duplicating them. A SCIP notification number on a supplier document indicates that the notification has been made for that article.

Supplier declarations and what to ask a distributor

A RoHS or REACH declaration from a component manufacturer is a statement, based on its knowledge of materials and processes, that a part meets the stated requirements at the date of issue. It is evidence for your technical documentation, not a certificate issued by an authority. Its value depends on what it says precisely:

• RoHS: which version is covered (2011/65/EU including Annex II as amended by 2015/863, i.e. all ten substances), whether the part is compliant with or without exemptions, and if with, which exemption numbers.
• REACH: the date or edition of the Candidate List checked (a declaration ages with every update), and either the names of Candidate List substances above 0.1 % per article or a statement that none are present above that level.
• Scope: the exact part numbers, including plating and material variants, and whether accessories such as seals or backshells are included.
• Supporting data: availability of full material declarations, for example in the IEC 62474 format, when your own process needs substance-level data.

A distributor is a supplier of articles under REACH and so has its own Article 33 duty to pass on Candidate List information it has received. For RoHS, the distributor relays the manufacturer's declarations and should flag when they change. When requesting compliance information, ask for the manufacturer's current declaration for the exact part number, any exemptions relied on, the Candidate List version checked, and the SCIP notification number where an SVHC is declared. For custom cable assemblies, ask how compliance of every component — contacts, housings, cable, heat-shrink, overmoulding compound — is documented. More on sourcing documentation is in component sourcing, and a specialist can help interpret declarations against your requirements via technical advice.