The basis for RoHS and REACH substance restrictions are quite different. RoHS restrictions are based on hazards - if a substance is hazardous and there are alternatives, then it could be banned. REACH restrictions are introduced only if a risk to human health or the environment can be proven, it cannot be controlled and substitutes exist.
RoHS restrictions can be imposed without a full assessment of the impact of the possible alternatives. It is enough to show that there is a potential risk without evidence of an actual risk.
For example, lead is banned by RoHS but there is no evidence that its presence in electronics has or is harming human health or the environment. Also, the possible substitutes had not been identified when this restriction was imposed in 2002 and although less hazardous substitute solder alloys have since been found, their impact was not known until some years after the RoHS lead ban.
The impact of lead solder substitutes is now known because the US EPA carried out a life cycle assessment which shows that neither lead solders nor lead-free solders are clear "winners" overall as they each have different impacts.
REACH restrictions are based on lengthy risk assessments that consider research into the impact of the substance in its entire life cycle and also the possible alternatives. This also considers the control measures used by industry to minimize risk and social and economic issues. REACH restrictions are likely to be application specific where a risk is identified although total bans are also possible.
The other main difference is that RoHS bans substances present in electrical equipment that is within the scope of this directive. REACH affects all chemicals including those used to make the equipment (alloys, solvents, paints, etc.) and chemicals present in finished products of all types. There are very few exclusions and exemptions.
The impact of lead solder substitutes is now known because the US EPA carried out a life cycle assessment which shows that neither lead solders nor lead-free solders are clear "winners" overall as they each have different impacts.
REACH restrictions are based on lengthy risk assessments that consider research into the impact of the substance in its entire life cycle and also the possible alternatives. This also considers the control measures used by industry to minimize risk and social and economic issues. REACH restrictions are likely to be application specific where a risk is identified although total bans are also possible.
The other main difference is that RoHS bans substances present in electrical equipment that is within the scope of this directive. REACH affects all chemicals including those used to make the equipment (alloys, solvents, paints, etc.) and chemicals present in finished products of all types. There are very few exclusions and exemptions.
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