REACH (Regulation EC 1907/2006) enters into force with first registration related provisions across all EU member states.
REACH and RoHS
Restriction of Hazardous Substances (REACH and RoHS)
The EU Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation (REACH) and Restriction of Hazardous Substances Directive (RoHS) require any company placing products on the EU market to identify and restrict hazardous substances across their supply chains, with mandatory Substance of Very High Concern (SVHC) disclosure under REACH, SCIP database notifications under the EU Waste Framework Directive, and hard substance limits with CE marking requirements under RoHS.
Next deadline:
REACH - August 4, 2026: Producers and importers of articles containing n-hexane or Bisphenol AF above 0.1% by weight per article, with total quantities exceeding one tonne per year, must notify the European Chemicals Agency (ECHA) under Article 7(2). Both substances were added to the SVHC Candidate List on February 4, 2026. The Candidate List is updated twice per year; each update triggers immediate Article 33 communication obligations for any affected product across the full catalogue.
RoHS - December 11, 2026: RoHS Exemption 6(a), which permits lead as a free machining alloying element in steel, expires for product categories 8, 9, and 11. No renewal is possible for these categories. Manufacturers whose products rely on this exemption must determine before this date whether narrower replacement exemptions apply or whether reformulation is required.
Regulation timeline
What the regulation requires
REACH and RoHS are the EU's primary frameworks for hazardous substance control in products placed on the EU market.
REACH applies across all product categories to manufacturers, importers and downstream users. Article-handling companies must screen products against the SVHC Candidate List, communicate SVHC presence above 0.1% by weight per article under Article 33, and submit article data to the SCIP database. The Candidate List contained 253 entries as of February 2026, and is updated twice per year.
RoHS applies to manufacturers and importers of electrical and electronic equipment. It restricts ten hazardous substances above defined concentration thresholds and requires CE marking. Where substitution is technically infeasible, time-limited exemptions apply and must be actively monitored.
Common REACH and RoHS implementation challenges
The SVHC Candidate List expands twice per year
Each addition triggers immediate Article 33 communication obligations and SCIP notification requirements across every affected product. Companies with large catalogues must cross-reference every update against existing products and material declarations.
Material declaration data rarely arrives at the substance level
Whether a product contains an SVHC above 0.1% by weight depends on supplier data that may be two or three tiers removed from the buyer. Spreadsheet-based approaches cannot maintain Full Material Disclosures at the scale the Candidate List expansion requires.
RoHS exemptions are time-limited and tied to specific product categories
More than 200 exemptions exist across Annex III and Annex IV, each with its own expiry date. Several major exemptions expire in late 2026 and mid-2027, with no renewal possible for some categories. Renewal applications must be submitted no later than 18 months before expiry. Tracking which exemptions apply to which products, verifying whether reformulation is technically feasible, and submitting renewal applications before expiry requires systematic coverage of the full portfolio, not ad hoc review.
REACH and RoHS documentation standards are independently enforceable
SCIP dossiers, Article 33 communication records, RoHS declarations of conformity, substance test reports, and CE marking documentation must be current, traceable, and product-specific. Market surveillance authorities can inspect either framework at any time.
Fulfill REACH and RoHS obligations without separate workflows
The osapiens HUB for Product Compliance maps supplier declarations against both frameworks simultaneously, generating SCIP notifications, Article 33 communications, and RoHS declarations of conformity from the same data set.
Screen products against the current SVHC Candidate List
The osapiens HUB for Product Compliance automatically screens supplier declarations against the live Candidate List when ECHA adds new substances. Affected products are flagged and Article 33 communications are generated from collected supplier data without manual reformatting.
Submit SCIP dossiers directly from collected supplier data
The osapiens Disclosure Management module validates and submits SCIP dossiers to the ECHA SCIP database using material data collected through the Supplier Portal. When product formulations change or new SVHCs are added, re-submission triggers from updated supplier records without a separate outreach exercise.
Track RoHS exemption expiry across the full product portfolio
Exemption expiry dates are surfaced as action items before they affect product eligibility, with declarations of conformity, technical files, and substance test records held in one compliance record per SKU. REACH and RoHS status flows into the Reporting Cockpit alongside CSRD-related sustainability disclosures.
Frequently asked questions
REACH applies to any manufacturer, importer, or downstream user of chemical substances, mixtures, or articles placing them on the EU market, regardless of product category or company size. RoHS applies specifically to manufacturers and importers of electrical and electronic equipment across eleven product categories, including household appliances, IT and telecoms equipment, consumer electronics, lighting, power tools, medical devices, monitoring and control instruments, and vending machines. Both regulations apply to companies headquartered outside the EU if they place products on the EU market through an EU-based importer or authorized representative.
SCIP (Substances of Concern In articles as such or in complex objects or Products) is a publicly accessible database operated by ECHA under the EU Waste Framework Directive. Producers and importers of articles placed on the EU market must submit a SCIP notification when an article contains an SVHC above 0.1% by weight; this obligation has applied since January 5, 2021 and is independent of Article 33 communication. SCIP data is used by waste management operators and recyclers to handle end-of-life products safely and informs circular economy enforcement priorities.
Exemption 6(a) for lead as a free machining alloying element in steel expires on December 11, 2026 for product categories 8, 9, and 11, with no renewal possible. Exemptions 6(b), 7(a), 6(c), and 7(c)-I expire on June 30, 2027 for most product categories; renewal applications for those exemptions were due by December 31, 2025. Manufacturers must assess before each expiry date whether products can transition to a narrower replacement exemption or whether reformulation is required.
Penalties are set and enforced by individual EU member states and vary by jurisdiction and infringement type. For REACH, Article 33 communication breaches have resulted in fines of up to €50,000 per individual infringement in some member states; market surveillance authorities may also order product withdrawal. ECHA coordinates cross-border REACH enforcement through its REF-10 audit program, with increased joint inspection activity signaled for 2026 to 2027. RoHS non-compliance can result in market bans, CE marking revocation, mandatory product recall, and administrative fines; EU-wide market surveillance data published in 2025 found that nearly half of electronic products tested failed basic RoHS requirements.
No. On April 27, 2026, EU Environment Commissioner Jessika Roswall confirmed before the European Parliament that the comprehensive REACH revision plan would not proceed. Current obligations remain in force unchanged, with targeted updates continuing through biannual Candidate List updates, Annex XIV authorization decisions, and Annex XVII restrictions. A PFAS restriction proposal covering consumer uses in cosmetics, food packaging, and outdoor gear is expected from ECHA by the end of 2026.
The osapiens HUB for Product Compliance stores a single compliance record per product covering REACH, RoHS, PPWR, and PFAS obligations simultaneously. Supplier declarations collected through the osapiens Supplier Portal feed SCIP dossiers, Article 33 communications, and RoHS declarations of conformity from the same data set. When ECHA updates the SVHC Candidate List, the platform flags affected products across all applicable obligations without a separate review cycle per framework.
