Consumer Compact | Electrical and Electronics
REACH is a horizontal legislation controlling the risks associated with chemical substances throughout their whole life cycle, while RoHS is a product-specific vertical legislation focuses on hazardous substances in electrical and electronic equipment (EEE). Although their scopes partially overlap, they were designed to be complementary.
Scope of RoHS 2
On 21 July 2011, RoHS 2 Directive (2011/65/EU) on the restriction of the use of certain hazardous substances in EEE, came into force, and required EU member states to implement national measures by 2 January 2013. The purpose of the Directive is to protect human health and the environment through banning the placing on the market of products that contain hazardous substances in specific concentrations.
Although the scope of RoHS does not cover the manufacturing process, risks arising at that stage have already been considered for the listing of substances in Annex II of the Directive. Such methodology of substances listing is consistent with the one under REACH. When conditions for the placing on the market of EEE are being established, RoHS takes into consideration waste management and recycling, which have a greater potential for exposure of humans and the environment than the manufacturing process does.
A Common Understanding
REACH applies to all substances (in mixtures or in articles), including those in EEE that fall under the scope of RoHS. This shows where the scopes of the two legislations overlap. However, based on the European Commission Document “REACH and Directive 2011/65/EU (RoHS) – A Common Understanding” (Doc. CA/36/2014), RoHS should be given priority over REACH for issues concerning the use of substances in EEE. The document explores the management of future regulatory action on the same chemical substances under both REACH and RoHS. Specific scenarios concerning restrictions and authorisation requirements are presented.
Restriction of substances under RoHS vs restriction of substances under REACH Annex XVII
Restriction of substances under RoHS vs Authorisation of the use of substances under REACH
Consumer Compact | Electrical and Electronics
REACH is a horizontal legislation controlling the risks associated with chemical substances throughout their whole life cycle, while RoHS is a product-specific vertical legislation focuses on hazardous substances in electrical and electronic equipment (EEE). Although their scopes partially overlap, they were designed to be complementary.
Scope of RoHS 2
On 21 July 2011, RoHS 2 Directive (2011/65/EU) on the restriction of the use of certain hazardous substances in EEE, came into force, and required EU member states to implement national measures by 2 January 2013. The purpose of the Directive is to protect human health and the environment through banning the placing on the market of products that contain hazardous substances in specific concentrations.
Although the scope of RoHS does not cover the manufacturing process, risks arising at that stage have already been considered for the listing of substances in Annex II of the Directive. Such methodology of substances listing is consistent with the one under REACH. When conditions for the placing on the market of EEE are being established, RoHS takes into consideration waste management and recycling, which have a greater potential for exposure of humans and the environment than the manufacturing process does.
A Common Understanding
REACH applies to all substances (in mixtures or in articles), including those in EEE that fall under the scope of RoHS. This shows where the scopes of the two legislations overlap. However, based on the European Commission Document “REACH and Directive 2011/65/EU (RoHS) – A Common Understanding” (Doc. CA/36/2014), RoHS should be given priority over REACH for issues concerning the use of substances in EEE. The document explores the management of future regulatory action on the same chemical substances under both REACH and RoHS. Specific scenarios concerning restrictions and authorisation requirements are presented.
Restriction of substances under RoHS vs restriction of substances under REACH Annex XVII
Restriction of substances under RoHS vs Authorisation of the use of substances under REACH
By analysing these scenarios, the Document aims to establish a ‘common understanding’ on how chemicals under REACH and RoHS should be managed. The Common Understanding document should be taken into consideration in REACH Risk Management Options (RMO) analysis procedures, as well as in the framework of the 2020 Substances of Very High Concern (SVHC) roadmap.
Support with chemicals regulations
SGS is committed to supporting manufacturers and retailers with managing the use hazardous substances in consumer products. Furthermore, through its global expertize and network of chemical labs, SGS can help you in ensuring your products comply with relevant hazardous substances requirements on all relevant markets around the world.
Whether you are in need of hazardous substances testing or other third party verification, certification or inspection services, SGS is ideally positioned to provide the right solutions to all your business’s needs.
For more information, visit SGS RoHS Services.
Miranda LEE
SGS Hong Kong Ltd.
Consumer Testing Services
t: +852 2774 7123
About SGS
SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world.
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