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.

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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

1. June 2007

REACH (Regulation EC 1907/2006) enters into force with first registration related provisions across all EU member states.

4. August 2026

Article 7(2) notification deadline for n-hexane and Bisphenol AF, added to the Candidate List on February 4, 2026. Companies exceeding one tonne of affected articles per year must notify ECHA by this date.

Ongoing

Targeted substance-level updates continue through Annex XIV authorization decisions and Annex XVII restrictions. A PFAS-specific restriction proposal covering consumer uses is expected from ECHA by the end of 2026.

5. January 2021

SCIP database obligations take effect under the EU Waste Framework Directive. Companies must submit SVHC data to the ECHA SCIP database for all articles containing Candidate List substances above 0.1% by weight placed on the EU market.

Twice per year

ECHA updates the SVHC Candidate List. As of February 2026, the list contains 253 entries. Each update triggers immediate Article 33 obligations and SCIP re-submission requirements for affected products.

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2007

1. June 2007
REACH (Regulation EC 1907/2006) enters into force with first registration related provisions across all EU member states.
2021

5. January 2021
SCIP database obligations take effect under the EU Waste Framework Directive. Companies must submit SVHC data to the ECHA SCIP database for all articles containing Candidate List substances above 0.1% by weight placed on the EU market.
2026

4. August 2026
Article 7(2) notification deadline for n-hexane and Bisphenol AF, added to the Candidate List on February 4, 2026. Companies exceeding one tonne of affected articles per year must notify ECHA by this date.
Twice per year
ECHA updates the SVHC Candidate List. As of February 2026, the list contains 253 entries. Each update triggers immediate Article 33 obligations and SCIP re-submission requirements for affected products.
Ongoing
Targeted substance-level updates continue through Annex XIV authorization decisions and Annex XVII restrictions. A PFAS-specific restriction proposal covering consumer uses is expected from ECHA by the end of 2026.

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.

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