Registration, SVHCs, and What Electronics Manufacturers Need to Know
Originally enacted in December 2006, the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) is a safety regulation implemented by the European Union to manage the use of chemical substances in products manufactured, sold, and imported within the EU. The framework entered into force on June 1, 2007, and has undergone various updates, amendments, and other changes since, including annual expansions to its Substances of Very High Concern (SVHC) List. As the directive's name suggests, REACH rests on four primary elements: registration, evaluation, restriction, and authorization. First, it requires EU manufacturers and importers to register chemical substances with the European Chemicals Agency (ECHA), the EU agency responsible for managing and administering REACH. Second, the regulation mandates that the ECHA carry out regular evaluations of all registered chemical dossiers, otherwise known as compliance checks. Finally, REACH restricts the use of substances found to be dangerous to human health, bioaccumulative, or persistent in the environment. Chemicals restricted in this way can only be used through special authorizations granted by the ECHA.
While REACH manages chemical use in the EU in several different ways, its most prominent regulatory mechanism is the registration process. Companies manufacturing, selling, or importing chemical substances in the EU in quantities exceeding one metric ton annually are required to register those substances through REACH. To register a substance, organizations must assemble and submit a dossier covering a range of relevant information on the compound. Since REACH entered into force in 2007, thousands of businesses have registered more than 20,000 substances with the ECHA.
The ECHA requires companies to follow a "one substance, one registration" principle. This means that manufacturers and importers legally obligated to submit dossiers on the same substance must do so jointly, which avoids multiple dossiers for the same chemicals sitting in the ECHA database. All registrations and accompanying dossiers are submitted through the ECHA website. This joint-submission model keeps the database consolidated and ensures regulators evaluate a single, complete picture of each substance rather than fragmented filings from individual companies.
In addition to imposing reporting requirements on businesses manufacturing or importing chemicals within the EU, REACH also has a systematic process for identifying hazardous substances and restricting their use across the EU's 27 member countries. The legal framework allows both the ECHA and member states to recommend that specific compounds be added to the Substances of Very High Concern (SVHC) List, also referred to as the Candidate List, if they meet certain criteria outlined in the original REACH legislation. As of November 2024, there are 242 substances on the REACH Candidate List. A chemical may be designated an SVHC if it meets one of the following criteria:
Expansions to the Candidate List start with either an EU member country or the ECHA itself submitting a proposal for a new substance to be legally recognized as an SVHC. Once the proposal is submitted and published in an ECHA registry, known as the "Registry of SVHC intentions until outcome," individuals, parties, and other interested stakeholders have 45 days to submit comments related to the substance, its uses, and the proposed restriction. These public comments are reviewed by the ECHA's Member State Committee (MSC), the group responsible for making a final decision on the chemical's inclusion on the Candidate List. Once a substance is officially recognized as an SVHC, it is added to the ECHA Candidate List. Following inclusion, suppliers who choose to continue using the chemical are legally required to fulfill several obligations:
While REACH and the Restriction of Hazardous Substances (RoHS) are both environmental regulations administered by the EU, their similarities largely stop there. REACH is a complex, multipronged directive that imposes reporting requirements on businesses, maintains a comprehensive list of hazardous substances, and restricts the use of specific chemicals through its Authorisation List. RoHS is a far more straightforward, streamlined regulation. The initial law, which took effect in 2006, limits the use of six substances in electrical and electronic equipment (EEE) across all EU member states. Five years later, in 2011, the EU introduced Directive 2011/65/EU, commonly referred to today as "RoHS 2." This directive expanded the scope of the original RoHS by restricting the use of four additional substances in all EEE.
| Attribute | REACH | RoHS |
|---|---|---|
| Scope | Broad chemical safety regulation across all products | Restricts substances in electrical and electronic equipment (EEE) |
| Mechanism | Registration, evaluation, restriction, and authorization | Direct restriction of named substances |
| Substances Covered | 20,000+ registered; 242 on the SVHC Candidate List (Nov 2024) | Six substances (original); four more added under RoHS 2 |
| Took Effect | Entered into force June 1, 2007 | Original RoHS in 2006; RoHS 2 (Directive 2011/65/EU) in 2011 |
| Administered By | European Chemicals Agency (ECHA) | European Union member states |
The ECHA typically updates its Candidate List twice annually, often adding several new substances over the course of a full calendar year. In 2024, the agency voted to designate seven new chemicals as SVHCs. These substances are used in everything from coatings and adhesives to electronic components and plasticizers. Manufacturers, importers, and other suppliers distributing any of these chemicals in the EU must now adhere to the ECHA's requirements for using Substances of Very High Concern.
Turkey's landmark environmental regulation, officially called the KKDIK but frequently referred to as "Turkey REACH," was established to manage chemicals in the country and requires manufacturers and importers operating in Turkey to register their use. The KKDIK was originally enacted in 2017 by the country's Ministry of Environment, Urbanisation and Climate Change. Though the registration window was originally scheduled to close on December 31, 2023, the government extended the deadline by several years. As of late 2024, the KKDIK is set to roll out gradually over the next half-decade, with deadlines for in-scope businesses in 2026, 2028, and 2030. While the EU's REACH directive and the KKDIK share a number of similarities, there is one major distinction businesses should be aware of: unlike the EU regulation, Turkey's law requires covered companies to have their chemical registrations approved by a qualified expert.
REACH compliance lives or dies at the bill of materials level: a single SVHC above threshold in one component can pull an entire assembly out of compliance. Z2's software solution empowers companies to manage the design, supply chain, and sustainability of their products against REACH, RoHS, and related regulations. Built upon a comprehensive component database backed by full material disclosures, Z2 gives teams instant visibility into which parts carry SVHCs, which are clear, and which need attention first.
Users directly upload their BOM(s) to the Z2 platform
Parts in the BOM are matched against REACH and SVHC documentation in Z2
Instantly see which parts carry SVHCs, which are clear, or which need attention
Upload your own documents or coordinate with Z2 to contact suppliers
Z2 tracks REACH SVHCs across your entire BOM using full material disclosures, flagging every part that carries a Candidate List substance above threshold. Teams see compliant, non-compliant, and at-risk parts in one view, backed by source documentation.
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