REACH Compliance for Electronics: What EU Importers Actually Require

REACH is the EU’s main chemical regulation, and it applies to electronics sold in Europe even though most people associate chemical regulations with products like cleaning supplies or industrial materials. If you’re exporting electronics to EU customers, or if your EU buyers are asking for REACH documentation, here’s what the regulation actually requires and what getting compliant actually costs.

What REACH Is and Who It Applies To

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It’s EU Regulation 1907/2006. The regulation restricts hazardous substances in products sold in the EU market and requires supply chain communication about Substances of Very High Concern (SVHCs).

The legal responsibility under REACH falls on whoever places products on the EU market. That means your EU-based buyer, the company in Germany, France, or the Netherlands that imports from you, is the party with direct legal obligations to the EU regulator (ECHA, the European Chemicals Agency).

But your EU buyer can’t comply without information from you. They need to know what substances are in the products you’re selling them. So even though you’re not directly regulated by REACH as a US or Chinese supplier, your EU customers will pass down documentation requirements through their purchase orders and supplier agreements. If you can’t produce REACH compliance documentation, you won’t win or keep EU contracts.

This is standard practice across the electronics supply chain. Large electronics brands like Apple, Samsung, and Bosch maintain strict REACH substance requirements for all their component suppliers, including manufacturers in China. The requirement flows from EU law through the buyer down to you.

How REACH Differs from RoHS

Importers who know one of these regulations often assume they know the other. They’re related but distinct.

RoHS (Restriction of Hazardous Substances) restricts 10 specific substances in electrical and electronic equipment. It’s product-category specific, it applies to EEE (Electrical and Electronic Equipment) as defined in the RoHS directive. The restricted substances list is fixed by law and changes only through formal amendment. Limits are substance-specific (0.1% for most, 0.01% for cadmium).

REACH is broader in every dimension. It applies to all products, not just electronics. Its list of restricted substances, the SVHC Candidate List, currently contains more than 240 substances and gets updated twice a year. The threshold is 0.1% by weight of an article for triggering notification requirements. And REACH creates active supply chain communication obligations, not just a restriction on selling non-compliant products.

Both can apply to the same electronics product at the same time. A laptop might need RoHS testing to confirm lead, mercury, cadmium, and other RoHS substances are below limits, and separate REACH testing to confirm no SVHCs are present above 0.1%. You often get both in one test package from labs like SGS or Intertek, but they’re separate legal requirements from separate regulations.

The SVHC List and the 0.1% Threshold

The Candidate List of Substances of Very High Concern is ECHA’s running list of chemicals it has identified as having serious hazard properties. As of early 2026, the list contains more than 240 substances. ECHA adds new substances in June and December each year.

The 0.1% threshold is the trigger for supply chain communication requirements. If any article in your product contains an SVHC at a concentration above 0.1% by weight of that article, two things happen:

You must provide information to professional customers (B2B buyers) upon request. The information must include the name of the SVHC and sufficient instructions for safe use. The deadline is 45 days from the request.

You must provide information to consumers upon request within 45 days. “Information about the safe use of the article” is the minimum, including the SVHC name.

Note that the 0.1% threshold applies to each article in your product, not to the entire assembled product. An article is a manufactured object with a defined shape, surface, or design. A cable, a circuit board, and a plastic housing are separate articles within an assembled device. If your cable contains an SVHC at 0.3% of the cable’s weight, that triggers the notification requirement even if the cable only makes up 5% of the total product weight.

If the total product weight exceeds one tonne per year and contains SVHCs above 0.1%, there’s also a notification requirement to ECHA through their SCIP database (Substances of Concern in Products database). This obligation typically falls on the EU importer, but they’ll need substance information from you to complete it.

What Chinese Factories Typically Provide

Most Chinese electronics factories that regularly export to Europe have done REACH testing at some point. The typical document they’ll offer you is a REACH SVHC test report from a third-party lab.

These reports vary in quality. A solid REACH test report from an accredited lab will cover the current full SVHC Candidate List, identify the articles tested, provide detection limits for each substance, and show a pass/fail result for each substance against the 0.1% threshold.

A weak or outdated report might cover only a partial SVHC list (missing substances added after the report was issued), apply to a product model that isn’t quite the same as what you’re ordering, or come from a lab with questionable accreditation.

The age of the report matters. ECHA updates the SVHC list twice yearly. A report from 18 months ago doesn’t cover substances added since then. For current compliance, you want a report dated within the last 12 months that explicitly covers the full current Candidate List.

Test report validity is a practical judgment call, not a legal fixed period. A 12-month-old report is generally considered current by most EU customers. An 18 to 24-month-old report starts to raise questions. Anything older than two years needs retesting if the SVHC list has grown (it always has).

How to Request REACH Documentation from Your Supplier

When you’re placing an order with a Chinese manufacturer for products going to EU customers, request the following in writing before or at purchase order confirmation:

A REACH SVHC test report covering the full current ECHA Candidate List. The report must come from a third-party accredited laboratory, not from the factory’s own in-house lab. Ask for the lab name, accreditation number, test date, and a copy of the full report, not a summary certificate.

Confirmation of which product model and variant the test covers. Test reports apply to specific configurations. If you’re ordering a product with different materials, colors, or components than the tested version, ask whether those differences affect compliance.

A REACH declaration of conformity. This is a separate document from the test report, it’s the factory’s written statement that the product complies with REACH requirements. Some EU customers will accept this paired with a test report as sufficient documentation.

Keep copies of all REACH documentation you receive. Your EU customers may request them at any time, and having documentation ready demonstrates that you take supply chain compliance seriously.

What REACH Compliance Costs

Testing costs depend on product complexity and how many materials are in the product.

A standard REACH SVHC screening test for a simple electronics product runs $200 to $600. This covers screening the accessible materials for the full Candidate List. If everything passes, you get a clean report and you’re done.

More complex products with many different materials, plastics, coatings, and finishes require more samples from more parts. Full REACH testing for a multi-material electronics product can run $600 to $1,500 or more.

If your product fails, meaning the test finds an SVHC above 0.1% in one of the articles, you need to work with your factory to substitute the material or reformulate the affected component, then retest the changed component. Add another $100 to $400 for the retest. Material reformulation at the factory adds more time and cost.

The most common REACH failures in electronics are phthalates in PVC cables and soft plastics, brominated flame retardants in circuit board materials, and certain heavy metals in plating and surface treatments. Chinese factories that produce for EU markets regularly have cleaned these up, but factories primarily serving domestic or non-regulated markets may not.

Penalties for REACH Non-Compliance

REACH enforcement varies by EU member state because each country implements its own penalties under the framework of the regulation.

Germany and the Netherlands are known for active enforcement. German customs authorities conduct market surveillance on chemicals compliance, and the penalty structure for REACH violations in Germany includes fines that can reach into the hundreds of thousands of euros for significant violations.

France, Sweden, and Denmark also conduct regular market surveillance. Products found on the market with non-compliant substances can be subject to market withdrawal requirements, mandatory recalls, and financial penalties that vary by the severity of the violation and whether the company has a prior history.

The EU’s RAPEX database (now called the Safety Gate) publishes product safety notifications, including REACH violations. A listing on RAPEX is public and damaging to a brand’s reputation with EU retailers.

From a practical standpoint, the real risk for US exporters isn’t a direct fine, EU regulators can’t reach into your US bank account. The risk is that your EU customer faces the fine, the recall cost, and the reputational damage, and they pass those costs back to you through contract claims and they stop buying from you. Losing an EU contract over a REACH violation costs more than the testing would have.

Staying Current as the SVHC List Grows

The single biggest compliance mistake with REACH is doing a one-time test and treating it as permanent compliance. The SVHC list grows twice a year. A product that was fully compliant 18 months ago may have REACH issues today because ECHA added a new substance that’s present in your product.

Build a compliance calendar. Mark the ECHA update dates (typically June and December). When ECHA publishes a new Candidate List update, check whether any of the newly added substances are plausible in your product based on its materials. You can do this without testing, ECHA publishes detailed substance information, and your factory may be able to confirm via supplier declarations whether those substances are present.

When in doubt, retest. A REACH SVHC screen on an existing product model costs a few hundred dollars. That’s cheap compared to the cost of a compliance failure in your EU customer’s market.

FAQ

Can my Chinese supplier’s factory test count for REACH compliance? No. In-house factory testing doesn’t satisfy REACH documentation requirements for EU customers. The test must come from an accredited third-party laboratory. Labs like SGS, TUV Rheinland, Intertek, and Bureau Veritas operate test facilities throughout China and issue internationally recognized REACH test reports.

What happens if my product contains an SVHC above 0.1%? Your EU customer must provide information about the SVHC to their customers upon request. If the SVHC is a restricted substance under REACH Annex XVII, there may be a concentration limit you’re violating, that’s a harder problem. Most SVHC notifications are about communication obligations rather than outright bans. But your EU customer will likely require you to reformulate and retest before continuing orders.

Does REACH require Safety Data Sheets for electronics? Safety Data Sheets (SDS) are primarily required for substances and mixtures, not finished articles. However, if your product contains SVHCs above 0.1%, your supply chain communication obligations under Article 33 require you to pass information about those substances to buyers. Some EU customers request a form of SDS or Article 33 notification letter alongside the standard REACH test report.

Where do I check the current SVHC Candidate List? The full Candidate List is published on ECHA’s website at echa.europa.eu/candidate-list-table. You can download the list in multiple formats. ECHA also provides a free web tool (ECHA’s Substance Search) for looking up individual chemicals.