UK REACH vs RoHS for imports from China
UK REACH addresses chemicals in substances, mixtures and articles; RoHS restricts specified substances in electrical and electronic equipment. An electrical product can need checks under both. Ask for material declarations and evidence matched to the actual model. Cambridge China Bridge has its own staff in China to help check factory evidence.
Decide which checks your product needs
Start with the destination and the finished product’s function. This comparison concerns Great Britain. RoHS covers electrical and electronic equipment, including cables and spare parts, unless specifically excluded. For a powered product, check its scope before accepting a factory’s claim that RoHS does not apply.
UK REACH substance restrictions can also affect finished articles, including electrical goods. Passing RoHS therefore does not settle your UK REACH position. For registration, candidate-list substances and information duties, use our existing UK REACH importer guide. For the wider electrical compliance checklist, see importing electrical goods.
Compare what each restricts
UK REACH restrictions depend on the substance and its use. They can limit, ban or impose conditions on chemicals supplied alone, in mixtures or in articles. Ask the factory to identify the restrictions relevant to your materials and intended use, rather than request an unspecified ‘REACH certificate’.
RoHS controls cadmium, lead, mercury, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers, and the phthalates DEHP, BBP, DBP and DIBP. Its concentration limits apply to homogeneous materials. Ask for separate evidence for solder, coatings, cable insulation and plastic parts rather than a result averaged across the assembled product.
Ask the factory for a traceable evidence pack
Request the exact model and revision, photographs, a BOM, material specifications, supplier declarations and relevant laboratory reports. For UK REACH, ask which restricted substances and candidate list were assessed, and when. For RoHS, ask which materials each report covers. A report for another model or an unidentified plastic leaves a gap.
RoHS manufacturers must produce and maintain technical documentation and draw up a declaration of conformity. Ask for the signed declaration and the supporting file, not just a certificate cover sheet. Arrange access to the evidence before ordering; use testing and certification support when the factory cannot explain its documents.
Check reports and claimed exemptions
Compare the report’s sample description, photographs, material identification and results with your specification. Confirm the issuing laboratory and ask it to clarify missing scope or unclear results. A declaration is useful evidence, but an unsupported statement on factory letterhead gives you little to check.
RoHS allows time-limited exemptions for specific technical applications. If the factory relies on one, ask for the exact exemption, the component and application it covers, and confirmation of its current validity for Great Britain. Do not accept ‘lead is exempt’ as a complete explanation.
Keep production tied to the evidence
Put approved materials, component suppliers and document references into the purchase specification. Require the factory to flag substitutions before using them. If solder, pigment, plating or plastic changes, review the affected evidence and agree whether further testing is needed. See making production match the sample.
Keep an indexed pack linking the order, model, BOM revision, declarations and reports. Ask our China staff to compare production materials and component markings with that pack during factory checks. Physical inspection and laboratory evidence answer different questions; plan both around the materials that could change.
Frequently asked questions
Do I need both UK REACH and RoHS?
An electrical product can fall within RoHS and also face UK REACH substance restrictions. Check both against the product’s materials, function and intended market.
Does a RoHS report prove UK REACH compliance?
It does not settle the question. Compare the substances and materials assessed with the UK REACH restrictions relevant to your product, and request evidence for any gaps.
What documents should I ask a Chinese factory for?
Ask for the exact model, BOM, material declarations, relevant laboratory reports and, for RoHS products, the signed declaration of conformity and supporting technical documentation.
Can I reuse reports after a material change?
Review what changed and which report covered it. Ask for updated material evidence and agree further testing where the existing evidence no longer matches production.