In this article
What RoHS covers today
RoHS (2011/65/EU, recast) restricts ten categories of hazardous substances in electrical and electronic equipment. RoHS 3 (Directive (EU) 2015/863) added four phthalates — DEHP, BBP, DBP, and DIBP — bringing the regulated list to ten categories.
What REACH SVHC adds
REACH (EC 1907/2006) does not restrict substances — it requires communication. Any article containing a Substance of Very High Concern (SVHC) above 0.1% by weight triggers disclosure obligations and, in some cases, notification to ECHA.
Key 2024 changes
- Two new SVHCs added (4,4'-dihydroxybiphenyl and 2,4,6-tri-tert-butylphenol)
- Updated exemption list for lead in certain applications
- Stricter enforcement on resold e-scrap parts
- California's SB 1212 expanding electronics reporting
The single biggest practical change for OEMs in 2024 is the expansion of SVHC scope. Expect more communications from suppliers and tighter form-factor disclosures on datasheets.
Documentation you should keep
- Material declarations from your suppliers
- Test reports from accredited labs (where applicable)
- A live BOM compliance status
- Documentation retention for at least 10 years
Practical steps for OEMs
Audit your BOM annually for SVHC content above thresholds. Maintain a list of approved suppliers who can demonstrate compliance on demand. And build lead-time into your redesign cycles so a regulatory change does not derail a launch.
Compliance is not a checkbox at the end — it is a discipline that runs through sourcing, qualification, and lifecycle management. Build the muscle.
