REACH and RoHS Compliance in PLM: Data and Processes

Short answer

REACH and RoHS compliance in PLM means managing substance-level material data in the bill of materials so a company can prove its products meet EU chemical rules. REACH, Regulation (EC) 1907/2006, covers substances of very high concern and restrictions in all articles. RoHS, Directive 2011/65/EU, limits ten substances in electrical and electronic equipment.

Key takeaways

RoHS sets maximum concentrations per homogeneous material, while REACH Article 33 uses 0.1% weight by weight of the article.
The REACH Candidate List held 253 entries after the February 2026 update, and each update can trigger new communication duties.
The Commission set aside a full REACH revision in April 2026, and the Environmental Omnibus proposes to repeal the SCIP database.
Compliance in PLM depends on full material declarations from suppliers linked to parts and to the bill of materials.

How REACH and RoHS differ

Both laws restrict hazardous substances, but they work at different levels and suit different data models.

Aspect	REACH (EC) 1907/2006	RoHS 2011/65/EU
Products covered	All substances, mixtures and articles	Electrical and electronic equipment (EEE)
Substance scope	Candidate List of SVHCs, Annex XIV authorisation, Annex XVII restrictions	Ten restricted substances in Annex II
Threshold basis	0.1% w/w per article for SVHC communication; restriction-specific limits	Per homogeneous material
Limits	Varies by restriction	0.1% for lead, mercury, hexavalent chromium, PBB, PBDE and four phthalates; 0.01% for cadmium
Evidence	Article 33 communication, SCIP notification	Technical documentation, EU declaration of conformity, CE marking
Exemptions	Use-specific	Time-limited exemptions in Annexes III and IV

The four phthalates (DEHP, BBP, DBP and DIBP) were added by Delegated Directive (EU) 2015/863. RoHS exemptions expire unless renewed, so their validity dates must be tracked per part. The Commission consulted on further lead and cadmium exemptions during 2026.

Which REACH obligations matter most for product companies?

For article producers and importers, three REACH duties drive the data model:

Article 33 communication: if an article contains a Candidate List substance above 0.1% w/w, suppliers must give recipients enough information for safe use, and consumers on request within 45 days. Under the "once an article, always an article" principle, the threshold applies to each component article in a complex product.
Article 7 notification: notification to ECHA when an SVHC exceeds 0.1% and one tonne per year across the producer's articles.
Annex XVII restrictions: for example, limits on certain PFAS, lead in consumer articles, or microplastics, each with its own scope and transition dates.

ECHA updates the Candidate List about twice a year. After the February 2026 update it held 253 entries. Each new entry starts a review of existing products, which makes automated screening against the current list essential. A broad PFAS restriction is under evaluation at ECHA, with scientific committee opinions expected in late 2026.

Regulatory changes in 2025 and 2026

Two developments matter for planning. On 27 April 2026 the Commission confirmed it would not table a full REACH revision and would pursue targeted simplification through amendments to the REACH annexes instead. Separately, the Environmental Omnibus proposed on 10 December 2025 would repeal the SCIP database, which has required notifications of SVHCs above 0.1% in articles under the Waste Framework Directive since January 2021, and points to the Digital Product Passport as a future channel for this information. The proposal was still in the legislative process at the time of writing (October 2026), so SCIP obligations remain in force.

Which data does PLM need for substance compliance?

Compliance calculations require data at the lowest level of the product structure:

Level	Attributes
Substance	CAS number, EC number, Candidate List status, RoHS restricted flag
Homogeneous material	Mass, substance concentrations
Part or component	Material declaration (IPC-1752A, IEC 62474 based), supplier, declaration date, exemptions used
Assembly and product	Rolled-up SVHC presence per component article, RoHS status, SCIP number
Market	Declaration of conformity, applicable regulations per country

Full material declarations allow re-screening when lists change without returning to suppliers. Partial declarations, which only confirm compliance against a specific list version, have to be renewed after every update. Declarations should carry a date and the list version they refer to.

Embedding compliance in PLM processes

The aim is to assess compliance during design rather than after release. Typical integration points are part selection, where engineers see compliance status before choosing a component, and engineering change management, where a change cannot be released until substance data for new parts is complete. Compliance status should roll up through the bill of materials and be visible per product and market.

Several approaches exist. Enterprise suites such as PTC Windchill and Siemens Teamcenter include material compliance modules, mid-market PLM such as PTC Arena supports compliance data on parts, and specialist product compliance software often handles supplier data collection and regulatory content. AI-assisted compliance screening is increasingly used to extract substance data from supplier documents, with human review of results.

Frequently asked questions

What is the difference between REACH SVHC and RoHS restricted substances?

RoHS restricts ten named substances in electrical and electronic equipment, with limits per homogeneous material, and non-compliant products cannot be placed on the market unless an exemption applies. REACH SVHCs are substances on the Candidate List; their presence above 0.1% in an article triggers communication and notification duties but does not by itself ban the article. Restrictions under REACH Annex XVII are separate bans or limits.

How often does the REACH Candidate List change?

ECHA usually adds substances to the Candidate List twice a year, often in January or February and in June or July. After the February 2026 update the list held 253 entries, some covering groups of substances. Companies should screen products against each update, because communication obligations apply as soon as a substance is added, and SCIP notifications must be updated as well.

Is the SCIP database being abolished?

The Commission proposed repealing the SCIP database in its Environmental Omnibus of 10 December 2025, suggesting digital alternatives such as the Digital Product Passport. This is a proposal that the European Parliament and Council must still agree. Until an amendment is adopted and applies, companies supplying articles with SVHCs above 0.1% must continue to submit SCIP notifications to ECHA.

Sources

Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.