REACH and RoHS: Sure, you have met them, buddy?

REACH and RoHS -- I have had the companionship of these two very close friends for nearly two decades now. They have really been great and excellent buddies, and I cannot thank them enough!

A friend recently asked me whether India was following REACH and RoHS. For those unaware, REACH and RoHS are European Union regulations focused on restricting hazardous substances, but they have different scopes and focuses. 

REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) applies to a wide range of products and chemical substances, aiming to ensure their safe use throughout their lifecycle. 

RoHS (Restriction of Hazardous Substances) specifically targets electrical and electronic equipment (EEE), restricting the use of certain hazardous substances in these products. It is implemented in the EU as a CE marking requirement.

Following these regulations is critical for semiconductor manufacturing, should one plan for any exports to Europe. 

RoHS is product-specific (EEE), while REACH has a broader scope, covering many products and chemicals. RoHS focuses on a specific list of restricted substances in EEE, while REACH addresses a wider range of chemicals, including SVHCs. 

RoHS is primarily an EU directive. Similar regulations exist in other regions. REACH is also an EU regulation, but its requirements impact global manufacturers exporting to the EU. 

REACH and RoHS have different ways of handling substance limits. REACH limits substances on the SVHC Candidate List, requiring reports for amounts over 0.1% by weight. RoHS has specific limits, like 0.1% for lead and 0.01% for cadmium.

While on this, may I also point out WEEE, which stands for Waste from Electrical and Electronic Equipment.

SVHC stands for Substances of Very High Concern. These are chemical substances identified under the European Union's REACH regulation as potentially harmful to human health or the environment.

European Chemicals Agency (ECHA) is an agency of the European Union, which manages the technical and administrative aspects of the implementation of the European Union regulation REACH, located in Helsinki, Finland. ECHA has also prepared a list of SVHC.

ECHA CHEM is ECHA's public chemicals database, launched in early 2024. It includes data that companies have submitted in their REACH registrations, and information from the Classification and Labelling Inventory (C&L).

USA doesn't have direct federal equivalents, although, several states have adopted RoHS-like laws, and REACH compliance that can be crucial for businesses exporting to Europe.

There is no nationwide RoHS regulation in the United States. State-level requirements have been adopted. Several states—including California, New Jersey, Illinois, Indiana, Minnesota, New York, Rhode Island, and Wisconsin, etc.,—have enacted their own RoHS-like laws, often modeled after the EU RoHS Directive.

Add ESPR and DPP to my friends list too!
Just for the record, Ecodesign for Sustainable Products Regulation (ESPR) and Digital Product Passports (DPP) are also in regulation within Europe. 

ESPR replaces the Ecodesign Directive 2009/123/EC and introduces more extensive requirements across more product groups. It covers wider range of products, including textiles, furniture, paints, ICT and electronics, etc. It has a broader set of performance requirements, including energy efficiency, durability, recycle-ability, end of life, etc.

DPP is a digital tool that will be used to collect and share information about a product and its supply chain. DPP will

include information related to sustainability, environmental impact, circularity, Substances of Concern, value retention for reuse/ re-manufacturing/recycling. Companies need to make sure product passport exists, and meets both technical and data requirements, available to all stakeholders (with appropriate access rights). Information included is authentic, reliable and verified. 

First sightings
My first association with REACH and RoHS happened back in 2007-08, when I was based in Hong Kong. I had to visit the Hong Kong Science and Technology Park (HKSTP), a place that I later visited multiple times. Located in Pak Shek Kok, Tai Po, New Territories, Hong Kong, near Chinese University, this is a sprawling structure. There, I first learned about REACH and RoHS. 

Note that these standards are absolutely critical for building any climate-resilient semiconductor value chain! Also, the chemicals or banned substances that are listed are critical for manufacturing just about anything, besides semiconductors. Therefore, if you plan to export any manufactured good to Europe, do look them up.

RoHS and REACH were in full display at Asia Photonics Expo, Singapore, where, Pradeep's TechPoints was a media partner, and continues to be. There were a range of products on display. Key sectors, such as optical communications, semiconductors, lasers, sensing, optics, quantum technologies, and displays, were in prominence. 

At Leti Innovation Days 2025 in Grenoble, France, where Pradeep's TechPoints was also a media partner, there was a track on: Keys to sustainable ICs. It discussed how our society is facing significant environmental challenges — from climate change and resource depletion, to threats to biodiversity. Launching a sustainable IC industry capable of innovating to overcome these hurdles will require collaboration and partnerships on an unprecedented level.

At the recently-held Symposium on VLSI Technology & Circuits in Rihga Royal Hotel, Kyoto, Japan, there was a panel discussion on: “What can the semiconductor industry do for a greener society? The key discussion topics included energy-efficient technologies enabled by advanced VLSI and sustainable manufacturing. 

Now, can India try and achieve these? Well, it can! There is some talk about semiconductors in India, albeit, on a much lower, mature node technology. However, something will eventually come up from India by end of 2025. 

Till date, I haven't even heard anyone talk about RoHS, REACH, and even sustainable manufacturing in India. And, no, I have not added any MNCs to this list, who already have offices here. One hopes that India learns its lesson, and tries to develop something worthwhile in the future.

So, there you go! How did you like these reliable friends of mine? ;)