One Component, Two Denominators: RoHS and REACH Need Different Evidence
Decide whether an electronics substance request needs RoHS homogeneous-material evidence, REACH Article 33 SVHC communication, or both.
Signals to watch
- A buyer asks whether a ten-substance RoHS report also covers the current REACH Candidate List
- A supplier declaration states whole-product concentration but does not identify homogeneous materials or constituent articles
- A product approval is waiting for the evidence owner and communication owner to be named
A RoHS report does not automatically cover REACH Article 33, and an SVHC declaration does not prove RoHS compliance. The same component can require both records, but RoHS measures restricted substances in each homogeneous material while Article 33 asks about Candidate List substances above 0.1% weight by weight in an article or constituent article and the information that must follow it.
For a product-stewardship or chemical-compliance consultancy business-development lead, that difference turns a vague “REACH testing” enquiry into a definable service. The relevant Signal appears in authorised electronics OEM sourcing, contract-manufacturer, component-supplier and EU importer or distributor groups when a buyer asks whether one supplier file can satisfy both regimes. If it sits for a day, the buyer may define the work as a generic finished-product test and ask another provider to quote; a consumer Article 33 request also loses one day from its 45-day response period.
Same component, two denominators
Suppose a connector contains a brass contact, nickel underplate, tin coating and plastic housing. RoHS asks whether each homogeneous material in in-scope electrical and electronic equipment meets Annex II restrictions or has a valid exemption. A homogeneous material has a uniform composition throughout or cannot be mechanically separated into different materials. The brass contact and coating cannot simply be averaged with the whole connector or finished device.
REACH Article 33 asks a different question. When an article contains a substance on the current Candidate List above 0.1% weight by weight, the supplier must communicate sufficient information available for safe use, including at least the substance name. The Court of Justice and ECHA approach applies the threshold to a constituent article in a complex object, so the finished device’s total mass should not be used to dilute a component-level result.
The lists also differ. RoHS Annex II currently restricts lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP at 0.1% in homogeneous material, and cadmium at 0.01%, subject to scope and exemptions. REACH uses a changing Candidate List. A defensible Article 33 record therefore preserves the list version or date and the substance identity.
What the evidence owner must hand over
| Evidence question | RoHS route | REACH Article 33 route |
|---|---|---|
| Legal object | In-scope EEE and its homogeneous materials | Article or constituent article supplied |
| Concentration basis | Each homogeneous material | Candidate List SVHC above 0.1% w/w in the article or constituent article |
| Substance reference | Current Annex II restrictions | Candidate List version and SVHC identity |
| Qualification | Scope exclusions and valid Annex III/IV exemptions | Article 33 condition and sufficient safe-use information |
| Output | Evidence supporting RoHS conformity and technical documentation | Proactive B2B communication; consumer response on request |
| Recipient | Manufacturer/conformity-file owner and relevant supply-chain parties | Article recipient; consumer on request |
A shared material declaration can support both routes when it identifies the supplier part and revision, material or constituent-article location, substance by CAS or EC identity, concentration and measurement basis. But it does not finish either route on its own. RoHS still needs EEE scope, homogeneous-material mapping and exemption review. Article 33 still needs the current Candidate List, constituent-article identity, recipient and sufficient safe-use information.
Do not convert an XRF screening result into a universal answer. XRF means X-ray fluorescence, a screening technique that can identify certain elements; it does not directly resolve every restricted substance, polymer phthalate, exemption or article-level communication duty. The method must answer a defined evidence gap on a representative item.
Choose one of three service receipts
RoHS evidence repair is the first receipt when the buyer can identify the EEE, affected parts and missing homogeneous-material or exemption evidence. The deliverable may be a supplier-evidence gap list, targeted test plan or technical-documentation update. This is narrower than a general chemical inventory.
Article 33 communication support is the first receipt when a Candidate List substance and constituent article are known or credibly suspected and the immediate job is a recipient or consumer communication. Record the list date, substance name, affected article, concentration basis, safe-use information, recipient, language and dispatch date. Consumer requests must be answered free of charge within 45 days when the provision applies.
Combined substance and article discovery is appropriate when the same supplier record must be rebuilt for both routes. It should yield two explicit conclusions, not one “compliant” badge. One conclusion concerns RoHS restrictions and exemptions; the other concerns Article 33 communication. A RoHS exemption does not cancel Article 33, and Article 33 should not be confused with separate REACH Article 7 notification or SCIP database obligations.
The unknowns belong in the quote: EEE scope, constituent-article structure, homogeneous materials, Candidate List date, substance identity, concentration denominator, RoHS exemption, supplier role, recipient and available safe-use information. A cropped supplier declaration is a reason to investigate, not a positive or negative compliance decision.
For a RoHS-only complaint and technical-file repair, see when a marketplace asks for the missing RoHS record. WEEE registration routing concerns producer registration rather than substance evidence, which keeps these service scopes separate.
TOP Prospect can retain and prioritise fragments in Telegram groups the user connected and was authorised to access, with original message, source, time and review reason. A saved matching target in the current product does not automatically run or create candidates. It cannot inspect materials, test a component, determine legal scope, issue a declaration or send Article 33 communications. The Signal workflow keeps the qualified human owner in control.
Key facts
- RoHS and REACH Article 33 can both apply to one component, but they use different legal objects and outputs.
- RoHS Annex II limits are assessed at homogeneous-material level; cadmium has a 0.01% limit while the other listed substances have 0.1% limits.
- Article 33 uses the current Candidate List and a 0.1% w/w threshold for an article or constituent article.
- B2B Article 33 information is communicated proactively; a consumer can request it and, where applicable, must receive it free within 45 days.
- A RoHS exemption does not remove an independent Article 33 duty.
- One supplier declaration can contribute evidence to both routes without proving either conclusion by itself.
FAQ
Does RoHS compliance prove REACH Article 33 compliance?
No. The lists, denominators, scope tests and outputs differ. Candidate List substances extend beyond RoHS Annex II, and a RoHS file may lack constituent-article and safe-use information.
Does a REACH SVHC declaration prove RoHS compliance?
No. It may omit a RoHS substance, homogeneous-material result, EEE scope or exemption analysis.
What concentration basis does RoHS use?
The maximum concentration values apply to each homogeneous material, not merely to the average mass of the finished product.
What happens when a consumer makes an Article 33 request?
When the provision applies, the supplier provides sufficient available information for safe use, including at least the substance name, free of charge within 45 days.
Reviewed by TOP Prospect Editorial Team on 20 August 2026 against Directive 2011/65/EU, REACH Article 33 and current European Commission and ECHA materials. Product scope, exemptions and communication duties require the current legal texts and qualified review.
Frequently asked questions
Does RoHS compliance prove REACH Article 33 compliance?
No. RoHS and Article 33 use different substance lists, denominators, scope tests and outputs. A RoHS exemption also does not switch off Article 33.
Does a REACH SVHC declaration prove RoHS compliance?
No. It may not address every RoHS restricted substance, homogeneous-material concentration, EEE scope or applicable RoHS exemption.
What concentration basis does RoHS use?
RoHS maximum concentration values apply by homogeneous material. Cadmium is limited to 0.01% and the other Annex II substances to 0.1%, subject to scope and valid exemptions.
What happens when an Article 33 consumer request is received?
The supplier must provide sufficient available information for safe use, including at least the substance name, free of charge and within 45 days when the 0.1% w/w condition is met.
Sources and further reading
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