REACH and RoHS from China Supplier: EU Import Essentials for 2026

What is the difference between REACH and RoHS?

REACH governs chemicals in almost everything; RoHS restricts ten substances in electricals only. REACH — Regulation (EC) No 1907/2006 — controls hazardous substances in the goods, or “articles”, you place on the EU market, whatever the product category. RoHS — Directive 2011/65/EU — caps ten named substances, lead and cadmium among them, in electrical and electronic equipment. The two overlap without replacing each other, which is why compliance checklists by market list them as separate line items.

Does REACH apply to my product?

If it physically enters the EU, almost certainly yes. Furniture, acrylic displays, packaging, textiles and homeware all count as articles under REACH. Your headline duty is the Candidate List of substances of very high concern (SVHCs), which the European Chemicals Agency updates roughly twice a year: when an SVHC exceeds 0.1% of an article by weight, you must inform your customers, and since 2021 also notify the SCIP waste database. Build that check into your import compliance paperwork before you order, not at the border.

Does RoHS apply to my product?

Only if it has an electrical or electronic function — a plug, a battery, a circuit board, an LED strip. That catches more orders than buyers expect: a lit acrylic display or a sofa with built-in USB charging falls in scope, while the unlit or unpowered version of the same product does not. RoHS caps each restricted substance at 0.1% per homogeneous material (0.01% for cadmium) and is enforced through CE marking, so the paperwork travels with the CE file.

What should I ask my China supplier for?

There is no such thing as a “REACH certificate” — treat a generic one-page certificate as a red flag. Ask instead for third-party test reports from a recognised laboratory (SGS, Bureau Veritas, Intertek, TÜV) covering the actual materials in your product, an SVHC declaration checked against the current Candidate List, and — for anything powered — a declaration of conformity backed by RoHS test data per homogeneous material. Then tie the paperwork to a pre-shipment inspection, so the goods tested are the goods that actually ship.

Who is legally responsible — the factory or me?

You are. The EU obligations sit with the importer, not the Chinese factory. A supplier outside the EU cannot carry REACH or RoHS duties on your behalf; once goods clear customs under your name, the SVHC communication, the declaration of conformity and ten years of technical documentation are yours to produce on request. Budget laboratory testing into your landed cost from the first quotation — it costs far less than a border detention or a forced recall.