- Ask for full material declarations, not one-line statements.
- Record which Candidate List version and which RoHS exemptions each declaration relies on.
- List your PFAS lines now (seals, cables, lubricants, coatings), before the restriction is decided.
REACH: substances of very high concern
- REACH (Regulation (EC) 1907/2006) covers chemical substances, including those contained in articles such as components and assemblies.
- The Candidate List of substances of very high concern (SVHC) had more than 250 entries in 2026, and ECHA usually updates it twice a year.
- If an article contains a Candidate List substance above 0.1 % by weight, its supplier must give you enough information for safe use, at least the substance name (Article 33). The threshold applies to each article, including each article inside an assembly.
- Under the Waste Framework Directive, suppliers of such articles on the EU market must also notify ECHA’s SCIP database. The Commission proposed in December 2025 to repeal this duty; it applies until that is adopted.
- Separately, some substances need an authorisation (Annex XIV) or are restricted (Annex XVII). Chromium VI surface treatments, still common in aerospace, are a well-known example: authorisation covers their use in the EU, not imported articles, and ECHA proposed in 2025 to replace it with a restriction.
- There is no automatic defence exclusion: Member States can grant defence exemptions case by case (Article 2(3)).
RoHS: ten restricted substances
- RoHS (Directive 2011/65/EU, amended by 2015/863) restricts ten substances in electrical and electronic equipment: lead, mercury, hexavalent chromium, PBB, PBDE and four phthalates (DEHP, BBP, DBP, DIBP) at 0.1 %, and cadmium at 0.01 %, by weight in each homogeneous material.
- Time-limited exemptions (Annexes III and IV) allow some uses, for example lead in certain solders and glass. Each has an expiry date to watch; an exemption stays valid while its renewal is under review.
- Outside scope: equipment designed to be sent into space, and equipment needed to protect essential security interests, including arms, munitions and war material intended for specifically military purposes. The space exclusion covers flight equipment only: ground support equipment, test benches and the ground segment stay in scope. Check whether your product is excluded, and whether your customer still asks for RoHS parts.
PFAS: what is restricted, and what is coming
PFAS are a family of thousands of persistent fluorinated chemicals. In hardware they sit in PTFE and FKM seals and gaskets, fluoropolymer (PTFE, FEP, ETFE) cable insulation, PTFE-based RF laminates, PFPE lubricants (common in space mechanisms), fluorinated heat-transfer fluids and coatings.
Some are already restricted, such as PFOA and PFHxS under the EU POPs Regulation and PFHxA under REACH for certain consumer uses. A much broader EU restriction covering PFAS as a group was proposed in 2023. ECHA’s risk assessment committee adopted its opinion in March 2026, its socio-economic committee consulted on a draft opinion in spring 2026, and its final opinion is expected by the end of 2026; the Commission will then propose the restriction to Member States. Time-limited derogations are under discussion for several uses, including sealing applications, military and medical uses.
You do not need to wait for the final text: list the BOM lines likely to contain PFAS now, and ask those suppliers what they plan to change.
What to ask suppliers
- A full material declaration (for example in IPC-1752 or IEC 62474 format) rather than a one-line statement. It lets you re-check a part when the rules change, without going back to the supplier.
- A RoHS declaration that names any exemption the part relies on.
- A REACH SVHC statement that says which Candidate List version it was checked against.
- The SCIP notification number, where one applies.
- A statement on intentionally added PFAS, and the supplier’s substitution plans.
Track compliance per BOM line
- Store each declaration, with its date and the list version it refers to, against the BOM line.
- Re-check the BOM each time the REACH Candidate List is updated.
- Track RoHS exemption expiry dates for the parts that rely on them.
- Flag the lines likely to contain PFAS, and follow the restriction’s progress.
Where Procureezy fits
You can add RoHS or REACH compliance as a requirement in Procureezy: the platform looks for compliance information in supplier sources, links what it finds and helps you find alternatives for lines with no published compliance evidence or a declared non-compliance.