Before You Read
- Check the report or certificate number exactly as shown on the issued document.
- Compare the public verification status with the document version and issue information.
- Prepare product information and platform notices when requesting document review support.
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Core Issue: Regulatory Positioning Differences Between REACH and RoHS
REACH (EU Regulation (EC) No 1907/2006) is a regulation concerning the registration, evaluation, authorization, and restriction of chemicals, covering all chemical substances entering the EU market, including substances in articles. RoHS (Directive 2011/65/EU) specifically limits hazardous substances in electrical and electronic equipment (EEE), such as lead, mercury, cadmium, etc. The regulatory scope differs: REACH applies to almost all goods, while RoHS only applies to EEE and related accessories. Companies must determine applicability based on product category, composition, and use scenario; the two cannot be used interchangeably.
Applicable Product Examples
Products that may require a REACH test report include: various chemicals (e.g., cleaners, coatings), plastic products, textiles (e.g., azo dyes in clothing), phthalate content in toys, etc. Products that may require a RoHS test report include: mobile phones, computers, household appliances, LED lighting, electronic toys, power tools, and other electronic and electrical equipment. Some products may fall under both regulations (e.g., toys with electronic functions) and require separate reports for each.
Document Checklist and Platform Review Scenarios
On cross-border e-commerce platforms such as Amazon, TEMU, and SHEIN, certain product categories may be asked to submit REACH or RoHS compliance documents. Common platform review scenarios include:
- Electronic products: the platform may request a RoHS test report or declaration
- Toys, textiles, chemicals: the platform may request a REACH test report or screening for Substances of Very High Concern (controlled substance)
Documents recommended for preparation:
- For REACH: an inventory of chemical substances used in the product and components, a test report covering the controlled substance candidate list, and a Safety Data Sheet (SDS/MSDS)
- For RoHS: an XRF report or chemical analysis report demonstrating that the levels of lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, etc. meet the limit values
- Declaration of Conformity (DoC) or self-declaration based on testing standards
Platforms retain the final review authority. Before uploading documents, carefully verify specific product requirements and the latest platform rules.
Common Misunderstandings
Misunderstanding 1: A REACH report can replace a RoHS report
REACH and RoHS control different substances. REACH covers a broader scope (e.g., controlled substance), while RoHS limits six specific hazardous substances. The two cannot substitute for each other. If a product falls under both regulations, separate reports are may requestd.
Misunderstanding 2: Applicable scope of RoHS reports needs confirmation
RoHS is an EU directive; other regions (e.g., China RoHS, U.S. state-level RoHS equivalents) have different versions and limit values. When exporting to different target markets, consult local regulations and prepare corresponding reports.
Misunderstanding 3: Having a REACH registration number means full product compliance
REACH registration primarily addresses the substance itself. Even if a substance in an article is registered, the use of that substance in the article may still be subject to authorization or restriction. A simple registration number does not cover compliance requirements at the article level.
Pre-Submission Document Verification Checklist
- Confirm product category: Is it within the scope of the RoHS Directive (EEE)? Does it contain substances potentially restricted under REACH (controlled substance, authorized substances, etc.)?
- Check the substances covered in the report: Does the RoHS report include all six hazardous substances? Does the REACH report cover the current controlled substance candidate list (latest version – to be confirmed manually)?
- Review the issuing party information: Does the testing laboratory hold ISO/IEC 17025 accreditation?
- Check report timeliness: REACH and RoHS regulations and lists may be updated. Is the report from a reasonable period relative to the product manufacturing date?
- Refer to platform requirements: Different platforms may have specific rules regarding report format, issuing organization, and validity period. Follow the platform backend guidelines.
Pre-Submission Checklist
- Report or certificate number
- Product name, model and applicant information
- Issue date and applicable standard shown on the document
- Platform notice, QR code screenshot or document submission request when available
Public verification results are for document status checking only. Platform review outcomes depend on product information, applicable requirements and the platform review process.
Article FAQ
My product is a Bluetooth headset. Do I need a REACH report or a RoHS report?
Bluetooth headsets are electronic and electrical products and generally need to first meet RoHS requirements by providing a RoHS test report. At the same time, plastic and cable components in the headset may contain REACH Substances of Very High Concern (controlled substance).
Do REACH and RoHS reports have a validity period? Can they be used long-term?
REACH and RoHS reports themselves generally do not have a fixed validity period under the regulations. However, their practical usability depends on multiple factors, including regulatory updates (e.g., the controlled substance list is updated twice per year), changes in product formulation or materials, and platform upload rules.
Do the two reports need to be issued by the same laboratory?
No. REACH and RoHS reports can be issued by different laboratories that hold ISO/IEC 17025 accreditation. As long as the report content is complete, testing standards are clear, and relevant substances are covered, the reports can be used for compliance reference.
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