EU REACH, EU RoHS, and Lead

Question: How are lead and lead compounds treated under REACH and RoHS?

Answer:  EU RoHS includes both lead and lead Compounds, so any type of lead substance beyond lead itself (CAS 7439-92-1) is potentially in-scope. EU REACH includes specific lead substances including lead itself, but not all lead substances.

Additionally, the threshold for compliance under EU RoHS is at the homogeneous material level
while under EU REACH the threshold for compliance is at the article level. This results in situations where lead could be over the threshold for one regulation, but could be under the threshold for the other.

Definition of "homogeneous material" (EU RoHS): One material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different
materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive

Definition of "article" (REACH): An object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. See also What is an "Article" Under REACH?


Article content as of 2019-01-23.


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