RoHS and REACH: the material-compliance rules inside every robot component

When a Chinese robotics manufacturer ships a collaborative arm or an AGV into the European Union, the first technical hurdle is not software integration or CE marking—it is the chemical and hazardous-substance profile of every screw, cable, PCB, and seal. Two EU legal instruments dominate that profile: Directive 2011/65/EU on the restriction of hazardous substances in electrical and electronic equipment (RoHS) and Regulation (EC) No 1907/2006 concerning the registration, evaluation, authorisation and restriction of chemicals (REACH). They overlap, but they are not the same. Understanding the difference is critical for spare-part logistics, after-sales compliance, and the long-term liability of a service network.

The two regimes: what each one actually controls

RoHS is a product-specific directive. It applies to electrical and electronic equipment (EEE) placed on the EU market, and it caps the concentration of ten hazardous substances in homogeneous materials. Those substances are lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates (DEHP, BBP, DBP, DIBP). The limits are 0.1% by weight for most, and 0.01% for cadmium. The directive covers categories 1–11 of Annex I, which include almost all robotics hardware: industrial control units, sensors, actuators, and even spare parts that are placed on the market separately. A replacement motor controller or a new wiring harness is EEE in its own right, so it must meet RoHS limits.

REACH is broader. It is a chemicals regulation that applies to all chemical substances—whether in EEE, plastics, lubricants, paints, or even packaging. REACH does not set product-level concentration caps in the same way as RoHS. Instead, it requires manufacturers and importers to register substances manufactured or imported above one tonne per year, to communicate information down the supply chain, and to comply with restrictions or authorisation requirements for substances of very high concern (SVHCs). The candidate list of SVHCs is updated regularly, and any article containing a listed substance above 0.1% weight-by-weight triggers a communication duty to downstream users and, upon request, to consumers. For a robot, that could mean a plastic housing containing a flame retardant that is not yet banned but is on the candidate list.

How they interact in a robot’s life cycle

RoHS and REACH are complementary. RoHS bans specific substances in EEE; REACH manages a wider universe of chemicals, including those not yet restricted. A substance can be restricted under REACH (e.g., certain phthalates) and also be listed in RoHS Annex II. In practice, a spare part must comply with both: RoHS for the homogeneous material, REACH for the substance’s registration status and any SVHC communication. For a service network, this means that a replacement part sourced from a non-EU supplier must be verified against both regimes—not just one.

There is also a temporal dimension. RoHS has been amended several times (e.g., the 2015 phthalate addition), and REACH restrictions evolve. A part that was compliant in 2018 might not be compliant today if a new SVHC is added to the candidate list. This is why spare-part inventories need a compliance review at least annually, not just at initial market entry.

Spare-part impact: what a service technician must check

For a technician replacing a motor encoder or a battery pack, the compliance burden is indirect but real. The part must carry a CE mark that includes RoHS compliance, and the supplier must provide a Declaration of Conformity. Under REACH, the part’s material composition must be documented, especially if it contains any SVHC above 0.1%. In practice, this means that a service network must maintain a technical file for each spare part, including test reports or supplier declarations. Without that documentation, a customs inspection or a market surveillance authority can block the part at the border or demand its withdrawal.

One practical issue is that RoHS applies to ‘homogeneous materials’—a single material that cannot be mechanically disjointed. A cable is a homogeneous material? No, a cable has a copper conductor, a plastic insulation, and a connector—each is a separate homogeneous material. So a single cable can have multiple compliance points. REACH, by contrast, looks at the whole article and the substance concentration. This difference affects how you test and document.

Comparison table: RoHS vs REACH for robot spare parts

Aspect	RoHS (Directive 2011/65/EU)	REACH (Regulation (EC) 1907/2006)
Scope	Electrical and electronic equipment (EEE) and spare parts placed on the EU market	All chemical substances in any article, including EEE, plastics, lubricants, and packaging
Main mechanism	Restriction: concentration limits for 10 hazardous substances in homogeneous materials	Registration, evaluation, authorisation, and restriction of substances; SVHC communication
Key thresholds	0.1% by weight (0.01% for cadmium) per homogeneous material	1 tonne/year registration trigger; 0.1% w/w SVHC communication threshold per article
Spare-part impact	Every replacement PCB, motor, sensor, or cable must meet RoHS limits; CE marking required	Spare parts must be registered if they contain substances above tonnage; SVHC info must flow down the supply chain
Documentation	Declaration of Conformity, technical file, test reports	Safety Data Sheets (if applicable), SVHC declarations, registration numbers
Enforcement	Market surveillance authorities; penalties vary by member state	ECHA and national authorities; penalties vary by member state

Practical steps for a service network

For a local service network being set up to support Chinese robotics manufacturers, the immediate task is to build a compliance checklist for every spare part. That checklist should include:

Verify that the part has a valid CE mark and a Declaration of Conformity referencing RoHS.
Request from the manufacturer a REACH compliance statement, including any SVHC content above 0.1% w/w.
Maintain a database of material declarations for each part, updated at least annually.
Train technicians to recognise that a part without proper documentation is a liability, not just a missing paper.
For parts sourced from outside the EU, ensure that the importer of record fulfils REACH registration duties if applicable.

It is also wise to monitor the SVHC candidate list and RoHS amendments. The European Commission regularly updates both. A part that is compliant today may require a new declaration next year. A service network that ignores this risks having to recall parts or face fines.

What varies by country and what to verify

Enforcement and penalties are not harmonised across EU member states. Some countries have stricter market surveillance than others. For example, Germany and the Netherlands are known for active enforcement, while others may be less proactive. The legal text of RoHS and REACH is directly applicable in all member states, but the practical application—such as the frequency of inspections or the severity of fines—varies. A service network should check the national laws of each country where it operates, and also consider that the UK has its own version of RoHS (UK RoHS) and its own REACH regime post-Brexit. If the network serves the UK, separate compliance is required.

Another nuance: RoHS has exemptions. Some applications, such as certain lead-containing solders for high-temperature use, may be exempt. These exemptions are time-limited and must be reviewed. A spare part that relies on an exemption must have that exemption documented. REACH authorisation is different: if a substance is in Annex XIV, it cannot be used without an authorisation, which is granted for specific uses. A spare part containing such a substance might be legal if the manufacturer holds an authorisation, but that authorisation may not cover the spare part’s use. This is a subtle but critical point.

Conclusion: compliance is a continuous process

RoHS and REACH are not one-time checks. They are ongoing obligations that affect every component in a robot’s lifecycle, from initial design to spare-part replacement. For a service network, the practical implication is that compliance documentation must be as reliable as the parts themselves. A certified technician network being assembled must have access to up-to-date material data, and must be able to trace each part to its source. The cost of non-compliance is not just a fine—it is the loss of trust and the potential for a product recall. In the competitive European robotics market, that is a risk no manufacturer can afford.

Sources

EUR-Lex — Directive 2011/65/EU (RoHS) — https://eur-lex.europa.eu/eli/dir/2011/65/eu/oj (accessed 2026-05-28)
EUR-Lex — Regulation (EC) 1907/2006 (REACH) — https://eur-lex.europa.eu/eli/reg/2006/1907/oj (accessed 2026-05-28)