REACH gets mentioned in the same breath as RoHS often enough that the two start to blur together. They shouldn't. REACH is broader, more data-intensive, and considerably harder to manage manually once you're tracking substances down through several supplier tiers. Here's a practical breakdown of what REACH actually covers, where it overlaps with RoHS, and what a workable compliance process looks like for an electronics manufacturer.
What REACH actually is
REACH, the EU regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (Regulation EC No 1907/2006), is administered by the European Chemicals Agency (ECHA) and is one of the broadest chemical regulations anywhere. It governs how chemical substances are handled across their entire lifecycle, from manufacture and import through to their presence in finished products.
The key distinction from RoHS is scope. RoHS applies specifically to electrical and electronic equipment. REACH applies to chemical substances, mixtures and articles across every industry. For an electronics manufacturer, that means substance obligations don't stop at the finished product; they run deep into the bill of materials and across every supplier tier feeding into it.
The regulation's underlying principle is blunt: no data, no market. If a substance's risks can't be registered and managed, it has no business being used commercially. That single principle shapes how electronics companies need to approach material selection, supplier qualification, and documentation.
Why it's worth taking seriously beyond "it's the law"
Market access. Sell products containing restricted substances above threshold levels into the EU and you're not looking at a fine, you're looking at products that simply can't be sold there. For any manufacturer with EU customers, that's a direct revenue risk, not an abstract compliance one.
The SVHC list keeps growing. ECHA's Substances of Very High Concern candidate list currently runs past 240 entries and is reviewed twice a year. Articles containing an SVHC above 0.1% by weight need notifying to ECHA's SCIP database and disclosing to customers on request. This isn't a one-off check; it's an ongoing monitoring obligation.
It's becoming a de facto global baseline. REACH's framework has shaped chemical regulation well beyond the EU, with partial adoption or reference in the UK, Turkey and elsewhere. Getting REACH right increasingly sets you up for a wider set of markets, not just one.
Customers expect the paperwork. Full material declarations and certificates of compliance are now a routine part of OEM supplier qualification. Not having them ready can knock out an otherwise perfectly capable supplier before the conversation even starts.
REACH vs RoHS: where they actually differ
It's a question we get asked often enough to spell out plainly. RoHS sets concentration limits for a defined list of restricted substances in electrical and electronic equipment, backed by a Declaration of Conformity and CE marking. REACH works differently: registration requirements, SVHC disclosure obligations, an authorisation process for substances of highest concern, and use-specific restrictions, applied across all industries, not just electronics.
There's real overlap: phthalates like DEHP sit on both the REACH SVHC list and the RoHS restricted substance list, for instance. But compliance with one never implies compliance with the other. They have to be managed as separate obligations, even though the underlying BOM and supplier-declaration data can often be collected through the same workflow.
What tends to be restricted
Heavy metals. Lead, cadmium, mercury and hexavalent chromium show up under both REACH and RoHS, but with different thresholds and, under REACH, a broader range of article types in scope.
CMR substances. A large share of the SVHC candidate list is carcinogenic, mutagenic or reprotoxic material, including aromatic amines and PAHs that turn up as manufacturing intermediates. Worth watching closely in component and materials sourcing.
Phthalates. DEHP, BBP, DBP and DIBP are common in cable insulation, connectors and plastic housings, and appear on both the REACH and RoHS lists. Tracking these properly needs substance-level data from polymer suppliers, typically via full material declarations in the IPC-1752B format.
Building a REACH process that actually holds up
1. Know your role. Manufacturer, importer, downstream user, or only representative — each carries different obligations. Manufacturers and importers of substances above one tonne a year must register with ECHA; downstream users carry safe-use and, in some cases, notification duties.
2. Build a real substance inventory. Not just top-level assertions from suppliers, actual full material declarations mapped down to every component sourced.
3. Monitor the SVHC list automatically. It changes twice a year, and manually re-checking your entire BOM against it every time isn't a realistic long-term process.
4. Get supplier data collection under control. Safety Data Sheets and full material declarations are your primary evidence base. This needs a structured, repeatable process, not one-off email chases.
5. Track Annex XIV and XVII separately. Annex XIV covers substances requiring explicit ECHA authorisation to use; Annex XVII is the restriction list, closer in mechanism to RoHS. Both get revised over time.
6. Keep documentation audit-ready. SDS records, substance inventory data and customer communications all need to be current and retrievable, not reconstructed under pressure when a request comes in.
Quick answers to the questions we hear most
Is there a "REACH certificate"? No. There's no official certification mechanism. Compliance is demonstrated through documentation: registration records, SDS files, SCIP notifications and material declarations. "REACH CoC" is an informal industry term, not something ECHA issues.
Is UK REACH the same as EU REACH? No. Post-Brexit, the UK runs its own regime, administered by the HSE, structurally similar to EU REACH but operationally separate. Registering under one doesn't cover the other, so if you sell into both markets, you're managing two compliance obligations, not one.
Where do I check if a substance is restricted? ECHA publishes the SVHC candidate list, Annex XIV and Annex XVII publicly, along with the SCIP database. Worth subscribing to update notifications rather than checking manually on a schedule.
Where PLM data makes this manageable
The recurring theme across all of this is data: substance data, supplier data, and regulatory update data, all needing to stay connected to your actual BOM rather than living in disconnected spreadsheets. That's exactly the gap Windchill is built to close. Material and substance data sits centrally, linked directly to parts and assemblies, so when the SVHC list updates twice a year, affected products can be flagged automatically rather than rediscovered during a customer audit.
It also supports structured supplier data collection, including IPC-1752B format declarations, which takes a significant amount of manual chasing out of the process, and keeps REACH and RoHS data in the same environment as your product and BOM data, so declarations and reports can be generated on demand rather than assembled from scratch each time a customer or auditor asks.
Where we can help
If REACH and RoHS compliance is still living in spreadsheets and email threads with suppliers, or you're weighing up how Windchill's compliance and BOM management capabilities would fit your current process, we're happy to talk it through and, where useful, arrange a demonstration.