REACH vs RoHS vs SCIP vs PFAS: A Cheat Sheet

REACH is the EU regulation that governs chemicals in almost every product sold in Europe. RoHS restricts ten hazardous substances in electrical and electronic equipment. SCIP is the European Chemicals Agency (ECHA) database where suppliers report substances of very high concern (SVHCs) in their articles. PFAS is not a regulation at all, but a family of thousands of fluorinated chemicals the EU is restricting, mainly through REACH.

The four usually arrive together, in the same customer questionnaire or the same audit request, which is why compliance and engineering teams treat them as one topic. Mixing them up has a cost. A part that passes RoHS can still trigger a REACH disclosure and a SCIP notification, and a seal nobody flagged last year may fall under a PFAS restriction next year. This cheat sheet puts the four side by side, explains how they connect, and shows how to work out which ones apply to your product.

The cheat sheet: REACH, RoHS, SCIP and PFAS at a glance

Each row answers a question a customer or auditor is likely to ask about your product.

Why these four aren’t the same kind of rule

REACH is a regulation, which means the same text applies directly in every EU member state. RoHS is a directive, which sets goals that each member state writes into its own national law, so enforcement and penalties for RoHS vary by country.

SCIP is neither. It is a database created by the 2018 amendment of the EU Waste Framework Directive, which requires suppliers of articles to send ECHA the same SVHC information they already owe their customers under REACH. PFAS is a chemistry, not a legal instrument. You can’t be “PFAS compliant” in the abstract, only compliant with a specific PFAS restriction.

The four also ask different questions of your data. RoHS asks you to prove a substance is absent or below a limit, REACH and SCIP ask you to document where it is present, and PFAS restrictions ask whether it can be replaced by a deadline.

REACH: the umbrella chemical regulation

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is mostly aimed at companies that make or import substances. For manufacturers of finished products, the part that matters most is the Candidate List of SVHCs. When an article contains a Candidate List substance above 0.1% by weight, Article 33 requires the supplier to give business customers enough information for safe use, at minimum the name of the substance, and to answer consumer requests within 45 days.

REACH also restricts and authorizes. Restrictions under Annex XVII ban or limit a substance in specific uses, and they can apply to imported articles as well as products made in the EU. Authorization under Annex XIV means a substance can’t be used inside the EU without permission, but it doesn’t cover the substance in an imported article.

The Candidate List is the moving part. ECHA adds substances roughly twice a year, so a supplier declaration that was complete in January can be incomplete by July.

RoHS: ten restricted substances in electrical and electronic equipment

RoHS applies to equipment that depends on electric currents or electromagnetic fields to work, such as household appliances and industrial controls. The current directive dates from 2011, and a 2015 amendment added four phthalates that have applied since July 22, 2019. The ten restricted substances and their limits are:

• Lead, mercury, hexavalent chromium, PBB, and PBDE at 0.1%
• Cadmium at 0.01%
• The phthalates DEHP, BBP, DBP, and DIBP at 0.1%

The limits apply per homogeneous material, meaning any single material that can’t be mechanically separated, such as a solder joint or a plastic housing. RoHS also lists time-limited exemptions for uses where no substitute exists yet, such as certain uses of lead in alloys. Before placing a product on the market, the manufacturer prepares technical documentation, signs an EU Declaration of Conformity, and affixes the CE mark.

SCIP: reporting SVHCs to ECHA’s database

SCIP stands for Substances of Concern In articles as such or in complex objects (Products). Since January 5, 2021, every EU supplier of an article that contains a Candidate List substance above 0.1% by weight has to submit a notification to ECHA. That includes producers, assemblers, importers, and distributors. Retailers and others who supply only consumers directly are exempt.

A notification identifies the article, names the SVHC and its concentration range, states where in the article the substance sits, and gives safe use information. For a complex object such as a machine or a vehicle, the notification goes down to the component that contains the substance. That is the hardest part of SCIP in practice, because it needs a bill of materials that links each component to its supplier declaration.

ECHA publishes the data for waste operators and consumers. Because SCIP follows the Candidate List, every list update can create new notifications for products already on the market.

PFAS: a substance group, not a regulation

PFAS are per- and polyfluoroalkyl substances, thousands of synthetic chemicals built on carbon-fluorine bonds. That bond strength makes them useful in coatings, seals, gaskets, lubricants, and cable insulation, and it also means they barely break down in the environment.

Several PFAS are already regulated. PFOS and PFOA are banned under the EU POPs Regulation, PFOA since July 4, 2020. A group of long-chain PFAS (C9–14 PFCAs) has been restricted under REACH since February 2023, and a restriction on PFHxA in a defined set of uses applies from April 2026. Several PFAS, including PFOA, PFHxS, and the PFOA substitute known as GenX, are on the Candidate List, so they can already trigger Article 33 duties and SCIP notifications.

The bigger change is the universal PFAS restriction. The national authorities of Germany, Denmark, the Netherlands, Norway, and Sweden proposed it in January 2023 to cover the whole group, so that one PFAS can’t simply be replaced by another. ECHA’s Risk Assessment Committee adopted its opinion in March 2026, and the Socio-Economic Analysis Committee’s draft opinion supports the restriction with targeted derogations for specific uses. Its public consultation closed on May 25, 2026. The committee’s final opinion is still pending, and after that the European Commission drafts the restriction for member states to vote on.

Where they overlap: one part, four obligations

Take a brass connector inside an electronic control unit. Brass often contains a few percent of lead to make it easier to machine, and RoHS allows this under an exemption for lead in copper alloys, so the connector passes RoHS. Lead is also on the REACH Candidate List, and at a few percent it is well above 0.1%. The supplier owes customers Article 33 information, and the same fact means a SCIP notification at the level of the connector within the control unit. If the connector has a fluoroelastomer seal, it falls in scope of the universal PFAS proposal as well.

All four answers come from the same material data, and compliance with one rule rarely covers another.

Which ones apply to your product?

Four questions sort out most products.

1. Is it electrical or electronic equipment? If it needs electric current or electromagnetic fields to work, RoHS applies.
2. Is it an article placed on the EU market? If so, REACH applies, and you need SVHC data for every article in it.
3. Does any article contain a Candidate List substance above 0.1% by weight? If so, Article 33 communication and a SCIP notification apply, unless you supply only consumers directly.
4. Does it use fluorinated materials, such as PTFE coatings, fluoroelastomer seals, or fluoropolymer cable insulation? If so, current PFAS restrictions may apply, and the universal restriction likely will.

Answering any of these depends on supplier declarations in formats such as IMDS or IPC-1752A, mapped to your bill of materials down to the component. Our guide to material compliance covers the rules that sit next to these four, such as Prop 65 and TSCA, and the same data feeds the digital product passport.

FAQs

Is RoHS part of REACH?

No. RoHS is a separate EU directive that applies only to electrical and electronic equipment, while REACH is a regulation that applies to chemicals in almost every product. They overlap, because several RoHS substances are also on the REACH Candidate List, and a product sold in the EU usually has to meet both.

Who has to submit a SCIP notification?

Every EU supplier of an article that contains a REACH Candidate List substance above 0.1% by weight, including producers, assemblers, importers, and distributors. Retailers who supply only consumers directly are exempt.

When will the EU PFAS ban take effect?

There is no date yet. ECHA’s two scientific committees have to finalize their opinions, then the European Commission drafts the restriction and member states vote on it. Transition periods and derogations mean different uses will face different deadlines.

How Mimacom can help

Every rule in this cheat sheet reads from the same source: component-level material data that connects your design records to your suppliers’ declarations. Mimacom builds that foundation for manufacturers by connecting PLM, ERP, IMDS, and supplier portals into one record, then automating the screening against REACH, RoHS, SCIP, and PFAS so that a list update triggers a re-check instead of a manual review. Our material compliance solutions cover regulatory assessment, system integration, and operations.

For one of the world’s leading car manufacturers, we built a platform that reconciles design records with supplier material declarations in IMDS through AI-assisted matching. Analysis of an entire vehicle series now takes about two and a half hours instead of days, and up to 80% of the reconciliation runs automatically.

Four rules, one data problem

REACH, RoHS, SCIP, and PFAS differ in legal form and scope, which is why they cause confusion. Underneath, they depend on the same thing: knowing which substances sit in which component, from which supplier, against which version of each list. A manufacturer who can answer that once, in one system, can answer all four, and will be ready when the PFAS restriction and the next Candidate List update arrive.