By Acquis Compliance | Fri Jun 6 2025 | 2 min read
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For electronics manufacturers, navigating chemical regulations isn’t optional—it’s mission critical. If you're selling in California, the EU, or the UK, you're already dealing with Proposition 65, RoHS, and REACH.
While they all aim to protect human health and the environment, these three regulations differ wildly in their scope, enforcement, and business impact.
This blog breaks down what makes each regulation unique, and what you actually need to do to stay compliant across the board.
Proposition 65, RoHS, and REACH Regulation Overview
Core Differences: Prop 65 vs RoHS vs REACH
- Substance Lists & Thresholds
- Prop 65: Over 900+ chemicals; any level of exposure could trigger warning requirements unless it’s below the “safe harbor level.”
- RoHS: 10 restricted substances in EEE with ppm-level thresholds (e.g., 0.1% for lead).
- REACH: 200+ SVHCs tracked; registration or authorization required above 0.1% w/w in articles.
- Scope of Regulation
- Prop 65 applies to all consumer goods sold in California—even if manufactured outside the U.S.
- RoHS applies only to electronic equipment.
- REACH covers all chemical substances, including in finished goods, components, and mixtures.
- Compliance Triggers
- Prop 65: Triggered by consumer or occupational exposure.
- RoHS: Triggered by placing EEE on the EU market.
- REACH: Triggered by manufacturing, importing, or using chemical substances in the EU.
What Electronics Teams Must Do
- For Prop 65:
- Assess exposure pathways for each listed chemical in your product.
- Provide clear warnings (on product/packaging/website) if exposure exceeds safe harbor levels.
- Maintain supplier documentation and testing data for audits.
- For RoHS:
- Conduct substance-level testing or obtain supplier declarations.
- Compile a Technical File (EN IEC 63000 standard) to support CE marking.
- Manage Annex III & IV exemptions strategically.
- For REACH:
- Identify and report SVHCs over 0.1% in any article.
- Submit SCIP dossiers if placing articles in the EU.
- Monitor updates to Annex XIV (Authorization) and Annex XVII (Restriction) lists.
Where Prop 65 vs RoHS vs REACH Regulations Overlap
How Acquis Helps Electronics Manufacturers Navigate All Three
Acquis streamlines compliance across Prop 65, RoHS, and REACH with:
- Automated chemical screening at the part and article level
- FMD collection and validation from your entire supply chain
- Prop 65 warning logic and exposure-level flagging
- SCIP and Article 33 automation for REACH
- CE-mark documentation workflows for RoHS
One Platform. Three Regulations. Zero Guesswork.
If you're manufacturing or selling electronics into California or the EU, Acquis helps you simplify the most complex parts of Prop 65, RoHS, and REACH compliance.
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Prop 65 vs RoHS vs REACH
RoHS applies exclusively to electrical and electronic equipment (EEE) sold in regulated markets. In contrast, REACH covers chemical substances in virtually all products and materials in the EU, while Prop 65 targets consumer goods in California that may expose users to listed chemicals.
RoHS restricts six heavy metals and four phthalates in EEE (<0.1%, or 0.01% for cadmium) REACH limits a broader volume of chemicals including SVHCs across all products, with <0.1% thresholds. Prop 65 covers chemicals known to cause cancer or reproductive harm; no set % limit compliance depends on exposure risk
RoHS compliance is triggered by placing EEE on the EU market. REACH applies when manufacturing, importing, or using chemicals in the EU. Prop 65 is enforced when products may expose Californians above safe harbor exposure levels
RoHS : Use technical files, component testing, and CE marking. REACH : Requires substance registration, safety data, and possibly authorizations for SVHCs . Prop 65 : Requires warning labels unless chemicals are below safe harbor or exposure is negligible
RoHS includes specific exemptions (e.g., lead in solders). REACH has Annex XVII restrictions and SVHC listing processes. Prop 65 allows compliance if chemical exposure is below safe harbor levels , typically determined via toxicological risk analysis
RoHS is limited to electronic equipment, while REACH covers all products and chemicals, including mixtures and articles
RoHS ensures restricted substances are minimized in electronic parts. REACH ensures any chemical (even non-EEE) meets EU-wide safety standards. Prop 65 addresses chemical exposure risks for end-use in California. Together, they provide comprehensive protection across global markets