REACH — Chemicals Regulation for Electronics

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is an EU regulation (EC 1907/2006) governing chemicals manufactured or imported into the EU. For electronics manufacturers, the key obligation is the SVHC (Substances of Very High Concern) disclosure requirement — if a product contains >0.1% w/w of a listed SVHC, customers and consumers must be informed.

Why companies use it

·Legal obligation for any company placing products or chemicals on the EU market
·SVHC list is growing (now 240+ substances) — proactive material screening avoids compliance surprises
·Drives material substitution to safer alternatives before substances receive an authorisation restriction
·Customer supply chains increasingly demand REACH compliance declarations (IPC-1752A) for full BOM transparency

What hiring managers look for

·REACH compliance is a legal requirement, not optional — engineers must understand their disclosure obligations
·Knowing the difference between SVHC notification duties (>0.1% in article) and REACH registration (chemicals) is a basic competency
·Material engineers and compliance engineers work directly with the SVHC candidate list and must monitor it for new additions (updated twice yearly)
·Experience managing REACH compliance in complex multi-tier supply chains is a sought-after skill

Typical interview questions

What is the SVHC threshold and what must you do if your product exceeds it?

How is REACH different from RoHS in terms of what it regulates?

How do you manage REACH compliance when your product contains 500+ components from 50 suppliers?

What happens if a substance used in your product is added to the SVHC Authorisation List (Annex XIV)?

What is IPC-1752A and how does it support REACH compliance?

Common mistakes

·Confusing the 0.1% SVHC threshold with the RoHS concentration limits — they apply to different things (articles vs. EEE, homogeneous material vs. article weight)
·Monitoring the SVHC list only once a year — ECHA adds substances twice yearly and obligations change with each update
·Not communicating SVHC presence to B2B customers within 45 days of request — this is a legal obligation, not optional
·Treating REACH as a one-time assessment — ongoing surveillance of the SVHC and authorisation lists is required throughout the product lifecycle
·Assuming that RoHS compliance implies REACH compliance — they overlap but are distinct regulations with different scope and thresholds

Real engineering example

A power electronics company discovered that a high-performance thermal interface material used in their inverter design contained 0.18% DEHP — an SVHC phthalate. Although DEHP is also restricted by RoHS, the REACH SVHC threshold triggered an additional obligation to notify industrial customers within 45 days of their request and to inform the ECHA SCIP database. The company did not know about SCIP obligations until an audit. Implementing a SCIP submission process and material content management system resolved the compliance gap.

Topics covered

REACHSVHCchemicalsEU regulationcomplianceECHAhazardouselectronics

Related interview guides

Electronics Engineer →Manufacturing Engineer →