A European buyer asks for “REACH and RoHS compliance” in the same sentence, as if it were one certificate. It is not. They are different texts, with different scopes, and they place the burden on different people. Getting this wrong costs you either a lost order or a liability you did not know you had accepted.
What each one actually covers
- RoHS is a product rule. It applies only to electrical and electronic equipment, restricts a defined list of substances, and works like CE marking: a declaration of conformity, a technical file, and a mark on the product.
- REACH is a chemicals rule. It applies to substances — on their own, in mixtures, and inside finished articles — across every sector. Furniture, textiles, toys, packaging: all of it.
So a plastic chair has no RoHS obligation and a real REACH one. A power supply has both. A cable assembly sold as a spare part may have both, and people routinely handle only the first.
The word “importer” does not mean what you think
Under REACH, the importer is the party established in the European Union that brings the goods into EU customs territory. That is never the Chinese manufacturer. It is your European customer. Which means that when you ship a substance or a mixture, the registration obligation lands on them, not on you — and they know it.
This is why buyers hesitate. A new Chinese supplier can mean a new registration file, a cost, and a risk on their side. It is a commercial objection dressed as a technical question.
The mechanism that turns it into an advantage
REACH lets a non-EU manufacturer appoint an Only Representative — an entity established in the Union that takes on the registration in your place. The effect is immediate: your European customer stops being an importer and becomes a downstream user, with far lighter duties.
Few Chinese exporters do this, and the ones who do can say something their competitors cannot: buying from us does not create a registration burden for you. That sentence closes deals. The condition is that the representative actually covers your customer's volumes — an arrangement that covers only part of them is worse than none, because it gives false comfort.
The list that moves under your feet
REACH maintains a candidate list of substances of very high concern. It is updated roughly twice a year, and it grows. A product that was compliant when you designed it can acquire a notification and information obligation later, without anything about the product changing. Check the list against your bill of materials on a schedule, not when a customer asks.
If you sell electrical equipment under your own brand in Europe, be aware that RoHS treats an importer who markets under their own name as the manufacturer, with the full set of duties. Selling through a European distributor who rebrands your product moves that responsibility to them — which is often precisely what they are trying to avoid.
Where to read it yourself
Official pages, opened and checked on 26 September 2026. Where a rule changes, these are the addresses that change with it — this article does not.