Separate REACH and RoHS Declarations

Question: Why is it important to have separate declarations for RoHS and the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation?  

Answer: First, RoHS does not cover all REACH Substances of Very High Concern (SVHCs). Additionally, even though a substance restriction/disclosure may have the same percentage threshold maximum for both RoHS and REACH, it’s very important to understand how each regulation expects you to make that calculation. The RoHS threshold is at the homogeneous level, while the REACH threshold is at the article level.

This means that, while both RoHS and REACH might impose a limit of 0.1 percent weight by weight (w/w), a screw with a coating would be considered two different homogeneous materials under RoHS, but one article under REACH. Further, declarations for either must contain wordage explicitly demonstrating compliance. For example, if a declaration wordage focuses on thresholds, then a REACH declaration may not be sufficient for RoHS.

To learn more, there is a RoHS recast FAQ available on the European Commission’s website, as well as a guidance on ECHA Substances in Articles.  

 

This content is accurate as of March 29, 2019.

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