Key Takeaways
- RoHS restricts ten substances in electrical and electronic equipment; the limits apply per homogeneous material.
- REACH requires information to be passed on when an article contains a substance of very high concern (SVHC) above 0.1 % by weight – which also triggers notification to the SCIP database.
- Robust compliance requires up-to-date evidence from suppliers: declarations of conformity, material declarations and, where relevant, conflict minerals reports.
Anyone placing electronics on the EU market must be able to prove that the materials used comply with substance restrictions. This responsibility cannot be passed on to the supplier – but the provision of the necessary evidence can. In this fourth part of our series we give an overview of the most important regulations for electronic components and assemblies and show which documents you should request during procurement.
Note: this article provides a technical overview and does not replace legal advice. The current versions of the legal acts mentioned are authoritative.
RoHS: substance restrictions in electrical and electronic equipment
The RoHS Directive 2011/65/EU, supplemented by Delegated Directive (EU) 2015/863, restricts the use of certain hazardous substances in electrical and electronic equipment. The limits refer to each homogeneous material – for example the solder, the plating of a terminal or the package material of a component – not to the total weight of the assembly.
| Substance | Maximum concentration |
|---|---|
| Lead (Pb) | 0.1 % |
| Mercury (Hg) | 0.1 % |
| Cadmium (Cd) | 0.01 % |
| Hexavalent chromium (Cr VI) | 0.1 % |
| Polybrominated biphenyls (PBB) | 0.1 % |
| Polybrominated diphenyl ethers (PBDE) | 0.1 % |
| DEHP, BBP, DBP, DIBP (phthalates) | 0.1 % each |
Time-limited exemptions for certain applications are listed in Annexes III and IV of the directive – for example for lead in high-melting-temperature solders. These exemptions are reviewed regularly and may expire. If you rely on an exemption, keep an eye on its validity.
RoHS compliance is part of the CE marking of the end product. For procurement this means: every component and every assembly should be backed by a RoHS declaration of conformity from the manufacturer.
REACH: information on substances of very high concern
The REACH Regulation (EC) No 1907/2006 governs the registration, evaluation and restriction of chemical substances. For manufacturers and distributors of electronics, the Candidate List of substances of very high concern (SVHC) is particularly relevant. It is maintained by the European Chemicals Agency ECHA and is usually extended twice a year.
If an article – and that includes a single electronic component – contains a Candidate List substance in a concentration above 0.1 % by weight, Article 33 of REACH imposes information obligations:
- Professional recipients must be informed without being asked, at least with the name of the substance.
- Consumers are entitled to this information on request within 45 days.
Because the Candidate List grows regularly, a previously unremarkable part can suddenly be affected. REACH statements from suppliers should therefore be dated and refer to the version of the Candidate List.
SCIP database: notification obligation since 2021
Since 5 January 2021, companies that place articles containing SVHCs above 0.1 % by weight on the EU market must notify them to ECHA’s SCIP database. The legal basis is the Waste Framework Directive 2008/98/EC. The aim is to make information on substances of concern available all the way to waste treatment and recycling. The notification requires data from the supply chain – another reason to request complete material information from your supplier.
Conflict minerals: 3TG and supply chain transparency
Tin, tantalum, tungsten and gold (together “3TG”) are found in almost all electronics – in solders, capacitors and contact surfaces. Since 2021, the EU Regulation (EU) 2017/821 has required Union importers of these minerals and metals above certain volume thresholds to carry out supply chain due diligence. Even if you as a buyer of components usually do not fall directly under the regulation, many customers ask for evidence. The industry standard for this is the Conflict Minerals Reporting Template (CMRT) of the Responsible Minerals Initiative; for cobalt and mica there is the extended template EMRT.
Special considerations for Switzerland
Switzerland is not an EU member but has its own regulations that are largely aligned with the EU. Substance restrictions for electrical and electronic equipment are set out, for example, in the Chemical Risk Reduction Ordinance (ChemRRV). For deliveries to Switzerland, check which evidence your customers there specifically require.
Which compliance documents to request during procurement
| Document | Purpose |
|---|---|
| RoHS declaration of conformity | Confirms compliance with substance restrictions, incl. any exemptions used |
| REACH statement | Lists SVHCs above 0.1 % with the Candidate List version |
| Material declaration | Full substance composition, e.g. according to IPC-1752A |
| CMRT / EMRT | Origin of tin, tantalum, tungsten and gold, or cobalt and mica |
| Certificate of Conformity (CoC) | Confirms that the delivery meets the specification |
| Traceability data | Lot and date codes for traceability |
Practical tips for robust compliance
- Collect evidence per MPN: declarations should refer to the exact manufacturer part number, not to a product family.
- Check validity: request or reconfirm REACH statements after every Candidate List update.
- Include alternative parts: every second source needs its own documentation.
- Follow developments: further restrictions, for example on PFAS, are being discussed at EU level. Early information buys time for adjustments.
Depending on the product and agreement, Intelligent Components provides RoHS and REACH evidence, material certificates, CoCs and traceability documentation. Learn more about our approach on the Quality & Compliance page or browse our range of electronic components.
Frequently Asked Questions About RoHS and REACH
What is the difference between RoHS and REACH?
RoHS restricts ten specific substances in electrical and electronic equipment. REACH is a general chemicals regulation which, among other things, requires information to be passed on when articles contain substances of very high concern above 0.1 % by weight.
Which substances are restricted under RoHS?
Lead, mercury, hexavalent chromium, PBB, PBDE and the four phthalates DEHP, BBP, DBP and DIBP at 0.1 % each, as well as cadmium at 0.01 %, each based on the homogeneous material.
Who has to notify the SCIP database?
Companies that place articles containing substances of very high concern from the REACH Candidate List above 0.1 % by weight on the EU market, such as manufacturers, importers and distributors.
What is a CMRT?
The Conflict Minerals Reporting Template is a standardised form from the Responsible Minerals Initiative that suppliers use to disclose the origin of tin, tantalum, tungsten and gold in their products.
Do you need compliance documents for your BOM? Get in touch – we clarify in advance which documents are available for your parts.