Scope of REACH and RoHS declarations

Short answer

REACH and RoHS requests are based on different regulations; they are not interchangeable general quality certificates. The information to be requested from the supplier must be defined according to the product's composition, target market and context of use.

Source: S055, S105

Technical explanation

The European Commission explains REACH in terms of managing risks related to chemicals, providing information, and registration, evaluation, authorization and restriction. RoHS, on the other hand, is aimed at restricting certain hazardous substances in electrical and electronic equipment. These scopes are not the same as the pressure resistance of a hose or its compatibility with the chemical to be conveyed. Because substance lists and exemptions can change, the date and scope of an old declaration must be checked. The obligations applicable to a product are not assigned automatically based on the industry or material name.

Source: S055, S105

Topic-specific checkpoints

ItemDescription
REACHScope of substance and article obligations
RoHSElectrical/electronic equipment context
DeclarationProduct, date, list and exemptions
DistinctionRegulatory information vs. mechanical performance

Source: S055, S105

How to evaluate it in practice

In the declaration request, specify the product codes, target country, name of the regulation and the date or list used as the basis. Clarify the scope for rubber/plastic, metal plating and other components. Record the declared obligation instead of a vague field such as ‘REACH certificate’. Keep the chemical compatibility chart and the regulatory declaration as different file types. The necessary legal interpretation and the scope assessment of the product must be carried out by a competent advisor.

Original editorial recommendation; not a clause of a standard.

Before a scope decision is made

  • Have the target market and the product's role as a substance, mixture, article or within electrical/electronic equipment been determined?
  • Which of the registration, restriction, authorization or article communication obligations is the REACH request based on?
  • Have the RoHS scope and any possible exemption been evaluated only in the context of electrical/electronic equipment?
  • Does the supplier declaration cover the full product code, bill of materials, date and revision?
  • Have the substance list checked, the threshold and the exemption version been recorded?
  • Is the declaration being kept from use as evidence of pressure performance or fluid compatibility?

Source: S055, S105

Frequently asked questions

Does a RoHS declaration ensure that a hose is suitable for chemicals?

No. Restriction of hazardous substances and resistance to the chemical being conveyed are different evaluations.

Source: S055, S105

Source coverage

  1. S055
    RoHS Directive European Commission · accessed 2026-10-19 Scope: electrical and electronic equipment
  2. S105
    REACH Regulation European Commission · accessed 2026-10-19 Overview, Law and Protecting consumers sections; no detailed interpretation of obligations made

A194 · Revision 4 · Content date 2026-10-19 · Published 2026-10-20 · Translated from the Turkish original.