BOM Regulatory Compliance: RoHS, REACH and Beyond

Which regulatory frameworks apply to your Bill of Materials, what they require, and how to check compliance before selling into EU and US markets.

Regulatory compliance is the most legally consequential risk category in a BOM assessment. A product that ships with non-compliant components cannot legally be sold in the EU or US — and the liability sits with the manufacturer or importer. This guide covers the key regulatory frameworks that apply to most electronics BOMs, including those TekPulse currently screens and those on the product roadmap.

RoHS — Restriction of Hazardous Substances

RoHS (EU Directive 2011/65/EU, amended by 2015/863/EU) restricts ten hazardous substances in electrical and electronic equipment sold in the EU: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), DEHP, BBP, DBP, and DIBP. Non-compliance blocks CE marking and EU market access.

REACH SVHC — Substances of Very High Concern

REACH (Regulation EC 1907/2006) requires companies to communicate information about Substances of Very High Concern (SVHCs) in articles they supply. If an article contains more than 0.1% by weight of an SVHC, you must notify your customers and (for B2C) provide that information on request. The ECHA SVHC candidate list currently contains over 240 substances and is updated twice per year.

Unlike RoHS, REACH does not automatically prohibit the use of SVHCs — it requires disclosure and communication up the supply chain. Non-compliance means you cannot legally supply the article in the EU.

PFAS — Upcoming restrictions

Per- and polyfluoroalkyl substances (PFAS) are the subject of a broad restriction proposal under REACH, covering over 10,000 substances. Electronics-relevant uses include fluoropolymer coatings, PCB surface treatments, and semiconductor manufacturing chemicals. The restriction is expected to come into force progressively from 2026–2028. PFAS screening is on the TekPulse product roadmap.

SCIP — Substances of Concern In Products database

SCIP is an ECHA database under the Waste Framework Directive (2018/851/EU). Suppliers of articles containing SVHCs above 0.1% that are placed on the EU market must submit SCIP notifications. This is an active obligation — not a one-time registration. SCIP obligation mapping is on the TekPulse product roadmap; for now, REACH SVHC screening (which identifies the underlying SVHCs) provides the foundation for your SCIP compliance work.

TSCA — US Toxic Substances Control Act

The US TSCA (15 U.S.C. §2601 et seq.) restricts the manufacture, import, and sale of certain chemical substances in the United States. For electronics, the most relevant restrictions involve PCB (polychlorinated biphenyl) contamination in older components, PFAS under proposed Section 6 rules, and asbestos. TSCA compliance is enforced by the EPA; violations carry civil penalties of up to $56,460 per day per violation.

WEEE — Waste Electrical and Electronic Equipment

The WEEE Directive (2012/19/EU) does not restrict substances directly, but requires producers to finance the collection, treatment, and recycling of their products at end of life. Products must be registered in each EU member state where they are sold, and must carry the crossed-out wheelie bin symbol. While WEEE is a product-level obligation rather than a component-level one, BOM data (material composition, weight distribution) feeds the producer's WEEE reporting.

How TekPulse regulatory screening works

TekPulse currently screens RoHS 2 and REACH SVHC at assessment time. Every component MPN is cross-referenced against:

• RoHS substance declarations from manufacturer compliance portals
• ECHA SVHC candidate list (current version, updated twice yearly)

The result is a per-component regulatory flag set — not a single pass/fail. You can see exactly which substance triggered a flag and what the regulatory obligation is, making it actionable rather than just a warning count.