Materials Compliance · Hazloc Labs

RoHS & REACH for Hardware BOMs: Evidence That Survives Audits

Materials compliance fails quietly: a connector plating, a plastic flame retardant, or a battery chemistry that nobody owned in the BOM. RoHS and REACH are different regimes — treat them as such.

RoHS vs REACH in one table

Regime	Focus	Typical evidence
RoHS	Restricted substances in electrical/electronic equipment	Test reports, FMD, exemption claims
REACH	Substances of concern (SVHC) + restrictions; communication duties	SVHC declarations, SCIP where required, restriction checks

A workable BOM process

1. Identify articles vs substances/mixtures in how you sell the product.
2. Prioritize high-risk parts: plastics, platings, solders, cables, batteries, paints.
3. Collect Full Material Declarations (or equivalent) with revision control.
4. Track RoHS exemptions with expiry and redesign triggers.
5. For REACH SVHC above thresholds, prepare communication and SCIP submissions when applicable.
6. Gate ECOs: no silent alternate that invalidates declarations.

When suppliers will not answer

• Escalate with a short, specific ask (substances list + signing authority).
• Use accredited testing on worst-case parts when business risk is high.
• Document due diligence — market surveillance looks for process, not perfection theater.

FAQ

Is a RoHS “certificate” enough?

A vague certificate without substance data or scope is weak. Prefer FMD + test data for critical parts.

Do PFAS rules replace REACH?

No. PFAS restrictions are expanding in multiple jurisdictions. Add a PFAS watchlist alongside REACH/RoHS.

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