If you manufacture electrical or electronic equipment for the EU market, RoHS compliance is mandatory and REACH SVHC compliance is a supply chain obligation. Non-compliant products are refused at EU customs and withdrawn from shelves. For most manufacturers, this is primarily a supply chain management exercise — collecting declarations from your component suppliers.
RoHS
10 restricted substances in EEE — threshold limits
REACH SVHC
Candidate list updated twice yearly by ECHA
Declarations
Required from every component supplier in your BOM
RoHS and REACH are EU regulations restricting hazardous substances in products. RoHS restricts 10 substances (including lead, mercury, cadmium) in electrical and electronic equipment. REACH requires notification and potentially authorisation for Substances of Very High Concern. Your job: help collect supplier declarations and flag any components from new or changed suppliers.
RoHS
10 substances restricted in EEE
SVHC
Candidate list — 0.1% threshold
Declarations
Collected from every component supplier
Quick reference. RoHS: Directive 2011/65/EU (RoHS 2), amended by 2015/863/EU (RoHS 3 — adds 4 phthalates). 10 restricted substances with concentration limits (typically 0.1% w/w, cadmium 0.01%). Applies to EEE in 11 categories. REACH: Regulation EC 1907/2006. SVHC candidate list updated twice yearly by ECHA. >0.1% w/w in article = notification obligation to customers and registration on SCIP database. Authorisation list (Annex XIV) substances require authorisation to use.
RoHS 2 + 3
11/65/EU + 2015/863/EU
REACH SVHC
0.1% threshold — customer notification
SCIP database
EU waste database — SVHC article registration
RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) are EU regulations designed to reduce hazardous substances in products and the environment. RoHS is product-specific (electrical and electronic equipment). REACH covers all chemical substances used in any product.
RoHS 2002
First introduced
REACH 2006
Comprehensive EU chemicals regulation
ECHA
European Chemicals Agency — administers REACH
Mandatory for electrical/electronic products sold in EU and UKREACH SVHC candidate list updated twice yearly — compliance is ongoingSupplier declarations required from every component supplier
What’s on this page
01 —What it isUnderstanding RoHS & REACH
Two EU substance regulations — one for EEE products, one for all articles containing chemicals.
RoHS (Restriction of Hazardous Substances Directive 2011/65/EU) restricts 10 specific substances in electrical and electronic equipment. If your product is an EEE and is sold in the EU, it must not exceed the maximum concentration values for these substances in any homogeneous material.
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals, Regulation 1907/2006) is a broader chemicals regulation. For manufacturers, the most relevant obligation is the SVHC (Substances of Very High Concern) candidate list: if any article you supply contains an SVHC above 0.1% by weight, you must notify customers and register in the SCIP database.
The ECHA (European Chemicals Agency) updates the SVHC candidate list twice yearly — typically in January and July. Each update can add new substances. A product that was fully compliant in January may have an SVHC notification obligation after the July update.
RoHS and REACH are separate obligations with different substance lists. A substance may be regulated under one but not the other. Both must be assessed independently. Having a RoHS declaration does not satisfy REACH obligations, and vice versa.
👥 Illustrative case — details changed for confidentiality
The business
Electronic sensor manufacturer Bangalore · 65 employees, exporting to Germany and France
The trigger
Their EU distributor flagged that a customer was asking for a REACH SVHC declaration — specifically whether their products contained any Substances of Very High Concern above 0.1% by weight.
The challenge
They had RoHS compliance documentation from their BOM review 18 months earlier — but the SVHC candidate list had been updated 4 times since then. Two new substances had been added to the list in the last update, and one of their components potentially contained them.
Where Clicarity came in
They tracked their compliance programme in Clicarity. RoHS and REACH were separate sub-jobs in each product compliance review. When the SVHC list was updated by ECHA, the REACH sub-job was reopened with the new list. The quarterly SVHC review stage meant they caught the new substances before the customer asked.
The result
SVHC declaration provided within 5 working days. Distributor satisfied.
The quarterly SVHC review meant we found it before they asked. Without the process, we would have sent them a declaration that was 18 months out of date.
02 —Who needs itIs it right for you?
Do you actually need it? Honest answer.
✓ You need both
Manufacturers of electrical and electronic equipment for EU/EEA/UK markets
Component suppliers whose customers sell EEE in the EU
Any manufacturer supplying articles to EU customers who ask for REACH SVHC declarations
∼ REACH SVHC only
Manufacturers of non-EEE products (furniture, textiles, machinery) supplying to EU — REACH SVHC may apply even without RoHS
— Domestic India only
Products sold only in India — RoHS and REACH are EU requirements
03 —What it requiresWhat is checked
RoHS and REACH — what each requires from manufacturers.
1
RoHS: Identify all 10 restricted substances in your BOM
E.g. Review BOM for any solder (lead), plating (hexavalent chromium), or flame retardants (PBB/PBDE).Most common gap: Assuming solder is lead-free without supplier confirmation. Always collect material declarations.
2
RoHS: Collect material declarations from all component suppliers
Written declarations from every component and material supplier confirming RoHS compliance with concentration values.
E.g. IEC 62474 material declaration from each PCB component supplier. Confirm maximum concentration values per material.
3
REACH: Check SVHC candidate list for each component
Compare your BOM components against the current SVHC candidate list. Any component containing an SVHC above 0.1% by weight creates a notification obligation.
E.g. Check ECHA SVHC candidate list at echa.europa.eu/candidate-list-table. Use component CAS numbers for systematic checking.
4
REACH: Notify customers if SVHC above threshold
If an article contains an SVHC above 0.1% by weight, you must notify customers within 45 days of a request. Also register in the SCIP database for B2C products.
E.g. Customer asks: "Does product X contain substances on the SVHC candidate list?" — you must respond within 45 days.
5
Maintain compliance file and update when list changes
SVHC candidate list updated twice yearly. Compliance file must be updated each time.
E.g. Calendar reminder in January and July to check ECHA updates against your BOM.
6
RoHS technical documentation for EEE
For CE-marked EEE, RoHS compliance is evidenced through the technical file — test reports or supplier declarations supporting the DoC.
E.g. RoHS compliance documented in the CE technical file alongside LVD and EMC conformity evidence.
What inspectors really check
EU customs and market surveillance authorities can check RoHS compliance through product testing. REACH compliance is checked through supply chain requests — customers ask for SVHC declarations. Inability to respond to an SVHC request within 45 days is a REACH violation.
Gap analysis checklist — tick what you already have
BOM reviewed for all 10 RoHS restricted substances
Every component and material covered.
Supplier material declarations collected for all BOM components
IEC 62474 or equivalent.
SVHC candidate list checked against current BOM
Against most recent ECHA list — dated.
Customer notification sent if SVHC above 0.1% threshold
Within 45 days of request.
SCIP database registration done for B2C articles with SVHCs
EU waste information system.
Compliance file dated and next update scheduled
January and July SVHC list check dates.
0 of 6 complete
04 —Official bodyWho certifies in India
Who issues this in India — and how to verify it.
REACH is administered by ECHA (European Chemicals Agency). RoHS is enforced by EU member state market surveillance authorities. The SVHC candidate list is maintained on the ECHA website at echa.europa.eu.
For Indian exporters: Your EU importer or customer is your primary obligation point for REACH SVHC notifications. They will request declarations when their customers ask them. Responding within 45 days is a legal obligation — not a courtesy.
ECHA — SVHC candidate list
European Chemicals Agency. Current candidate list.
Based on echa.europa.eu. Actual timelines vary. Confirm with your CB.
RoHS & REACH Journey
Step 1
BOM review — identify substances of concern
All 10 RoHS substances + current SVHC list.
Step 2
Collect supplier declarations
Material declarations from every component supplier.
Step 3
Assess against thresholds
RoHS: homogeneous material limits. REACH: 0.1% w/w per article.
Step 4
Notify if threshold exceeded
Customer notification within 45 days. SCIP registration for B2C.
Step 5
Calendar reminder for SVHC updates
January and July each year.
Ongoing
Trigger review on supplier or BOM changes
Any component change may affect compliance.
▶Where to begin: Use the checklist in Section 3 to assess your readiness before contacting any CB.
RoHS threshold
0.1% w/w (0.01% for cadmium)
Per homogeneous material in the product.
REACH SVHC threshold
0.1% w/w per article
Customer notification obligation if exceeded.
SVHC list updates
Twice yearly (Jan & Jul)
Check echa.europa.eu after each update.
Customer response
Within 45 days of request
REACH legal obligation.
The SVHC candidate list grows with every update. A product that was REACH compliant in January may require a new customer notification after the July update adds a new substance. Build a calendar trigger — do not assume last year's assessment is still current.
06 —Find certified companiesHow to verify
How to find and verify certified organisations.
The ECHA SVHC candidate list is publicly available at echa.europa.eu. Product RoHS compliance is verified through market surveillance testing. Supplier declarations for REACH can be requested from any article supplier in the EU supply chain.
How to verify: To confirm whether any organisation holds a current RoHS & REACH certification, use the official register. Verify the issuing CB's accreditation at nabcb.qci.org.in.
Good records are the foundation. A process tracker builds them automatically.
Clicarity — Live Job Process Tracker & Bottleneck Identifier
Clicarity doesn't assess your substances. It tracks the compliance programme — ensuring RoHS and REACH checks happen on schedule, supplier declarations are collected, and the SVHC candidate list is reviewed every time ECHA updates it.
RoHS and REACH compliance is not a one-time exercise — the SVHC candidate list is updated twice yearly and your supplier base changes over time. In Clicarity, RoHS and REACH are tracked as separate compliance jobs for each product. Each job has stages for BOM review, supplier declaration collection, substance check, and declaration preparation. When the SVHC candidate list is updated, the REACH sub-job is reopened. Quarterly review stages ensure the compliance file stays current — not just accurate at the time of first assessment.
BOM review stage captures the total component count and flags which suppliers have not yet returned declarations — visible outstanding items.
RoHS and REACH checked as separate sub-jobs — different substance lists, different thresholds, different notification obligations if limits are exceeded.
SVHC candidate list review scheduled as a recurring job stage — triggered by each ECHA update so compliance is always against the current list.
Clicarity tracks the compliance declaration date alongside the last SVHC list update date — making it immediately visible when a declaration is older than the most recent candidate list.
📄 Job tracked in Clicarity
#RR-2026-01 — RoHS & REACH compliance — new electronic product
Compliance project initiated
✎Product name
✎Target markets (EU/UK/etc.)
▼Compliance officer
▼Design engineer
📅Target compliance date
→
Bill of materials review
✎BOM version
#Total components
▼Supplier declarations requested
▼Substances of concern identified
▼BOM owner
→
Supplier declarations collected
#Declarations received
#Declarations outstanding
▼Follow-up sent
▼Declarations verified
📅Collection complete
→
Testing (if required)
▼Test lab
✎Standards tested against
▼Test outcome
✎Report ref.
📅Report date
▼ Job splits — each component tracked independently
#RR-2026-01-A
RoHS restricted substances check
▼6 RoHS substances checked
▼All within limits
✎Declaration ref.
#RR-2026-01-B
REACH SVHC check
▼SVHC candidate list checked
#SVHCs above 0.1% w/w
▼Customer notification required
▲
Components rejoin as #RR-2026-01 — complete record of every branch, every data point, every sign-off preserved.
Compliance declaration prepared
▼RoHS DoC prepared
▼REACH SVHC notification drafted
▼Legal review
📅Date
→
Product labelling
▼RoHS mark on product
▼WEEE symbol on product
▼Labelling reviewed by
📅First despatch date
→
Ongoing monitoring
▼SVHC candidate list review scheduled
📅Next SVHC list check date
▼Supplier change notification process
▼Compliance file location
Wastage tracked:▰ RoHS and REACH checked as separate sub-jobs — different substance lists, different thresholds▰ SVHC candidate list review scheduled quarterly — the list is updated twice yearly▰ Compliance declaration issued only after both sub-jobs are complete
ⓘ Fields and stage names are fully customisable. This illustrates a typical electronic product — RoHS and REACH compliance assessment setup.
👥 Illustrative case — details changed for confidentiality
The business
Electronic sensor manufacturer Bangalore · 65 employees, exporting to Germany and France
The trigger
Their EU distributor flagged that a customer was asking for a REACH SVHC declaration — specifically whether their products contained any Substances of Very High Concern above 0.1% by weight.
The challenge
They had RoHS compliance documentation from their BOM review 18 months earlier — but the SVHC candidate list had been updated 4 times since then. Two new substances had been added to the list in the last update, and one of their components potentially contained them.
Where Clicarity came in
They tracked their compliance programme in Clicarity. RoHS and REACH were separate sub-jobs in each product compliance review. When the SVHC list was updated by ECHA, the REACH sub-job was reopened with the new list. The quarterly SVHC review stage meant they caught the new substances before the customer asked.
The result
SVHC declaration provided within 5 working days. Distributor satisfied.
The quarterly SVHC review meant we found it before they asked. Without the process, we would have sent them a declaration that was 18 months out of date.
Clicarity is a process tracking tool. It does not provide certification, consulting, or audit services.