RoHS and REACH for vape hardware

What RoHS covers

The RoHS Directive (2011/65/EU) restricts hazardous substances in electrical and electronic equipment. A vape device is electrical and electronic equipment, so a cartridge with a coil in it, a battery and a disposable are all in scope. The restricted substances include lead, mercury, cadmium, hexavalent chromium, certain brominated flame retardants and several phthalates. The directive has been amended, so work from the current consolidated text and annexes rather than an old copy.

The detail that catches buyers out is where the limit applies. RoHS restrictions apply to the homogeneous material, not to the finished device as an average. A device does not pass because the restricted content is small relative to its total mass. Every separable material has to pass on its own: the solder joints, the plating on the threads, the wire insulation, the board laminate, the magnet, the adhesive and each plastic. That is why a RoHS report on a device with an undocumented component change is worth less than it looks.

What REACH covers

REACH (Regulation 1907/2006) governs chemicals across the whole economy rather than electronics specifically. For a finished article such as a cartridge or a pod, the duties that usually bite concern substances of very high concern on the candidate list: communicating their presence down the supply chain, and notification duties where a candidate-list substance is present above the threshold set in REACH. The candidate list is updated periodically and grows, so a statement that does not name the version it was checked against is close to useless. REACH also carries restrictions on specific substances and uses, which can apply to a material in your device even when RoHS says nothing about it.

For empty hardware, REACH matters most in the vapour path, because those are the materials that meet the oil and then the user. Mouthpiece polymer, seals and O-rings, the wick or porous ceramic core, and the tank material all belong in the question. Buyers and their own downstream customers increasingly ask for this in writing, and a supplier that cannot produce it per material is telling you something.

The two side by side

RoHS 2011/65/EU and REACH 1907/2006 compared

	RoHS 2011/65/EU	REACH 1907/2006
What it regulates	Named hazardous substances in electrical and electronic equipment	Chemicals generally, including substances in finished articles
Why your device is in scope	Because it is electrical and electronic equipment	Because it is an article made of materials, powered or not
Where the limit is applied	To each homogeneous material inside the device	To the substance, with duties triggered at article level
The list you check against	The restricted-substances annex, as amended	The candidate list of substances of very high concern, as updated
Usual evidence	A test report against the SKU, plus a supplier declaration	A REACH and SVHC statement, plus contact-material declarations
Part of CE marking	Yes. Named on the EU Declaration of Conformity	No. Produces no CE mark and does not appear on the declaration
Where it bites hardest on a vape	Solder, plating, board, wiring and structural plastics	The vapour path: mouthpiece, seals, wick or ceramic, tank
Who has to hold the evidence	The manufacturer, and you if you brand the device	The manufacturer and the importer, in their own right

Evidence to demand per SKU

Ask per SKU and per revision, never per range. A supplier who sends one PDF for eleven products has given you a marketing document.

• A RoHS test report naming the exact SKU and revision. Check that the sample described in the report matches the part in your hand, including colour, plating and mouthpiece material, because those are the parts that change quietly between runs.
• The laboratory and its accreditation. A report with no lab name, no date and no scope statement cannot be followed up when a customer or an authority asks.
• A material breakdown showing what was tested. The point of RoHS is per material, so a report that tested the device as one lump has not tested what the directive asks about.
• A REACH and SVHC statement naming the candidate list version. Undated statements age invisibly. Re-request them when the list is updated and when a component changes.
• Contact-material declarations for the vapour path. Named per part, not as a single sentence covering the device.
• A change-notification commitment in writing. The evidence is only as current as the bill of materials, so agree that the factory tells you when a component or supplier changes.

Heavy-metal questions on cartridges sit next to this rather than inside it, and they are handled in cartridge heavy metal testing. The wider document set is listed in supplier documentation to request. For the products themselves, start with empty 510 cartridges.

How they relate to the CE declaration

RoHS is CE-marking legislation. REACH is not. That single difference explains most of the confusion.

The EU Declaration of Conformity is a single document in which the manufacturer states that the product meets every piece of applicable CE legislation at once. For a battery vape device that normally means at least RoHS and electromagnetic compatibility, alongside the relevant safety rules for the cell and charging. RoHS should be named on the declaration among the legislation applied, and the RoHS evidence should be in the technical file behind it. REACH appears in neither. A device can therefore carry a complete and valid declaration while the REACH file is empty, which is exactly the gap a buyer inherits without noticing.

Who signs matters as much as what it says. The manufacturer draws up and signs the declaration, and putting your own brand on a device makes you the manufacturer in EU law, so the declaration and the technical file become yours. At that point the RoHS report and the REACH statements become the contents of a file you must hold and produce on request. Build it at first order, not at first enquiry from an authority. See the EU compliance pillar for how this fits with WEEE, the Battery Regulation and GPSR, and CE marking for vape hardware for what the declaration itself has to contain.

This page is general guidance for trade buyers and is not legal advice. Regulations are amended and lists are updated. Confirm the current requirements and your own obligations with a qualified specialist before you place a product on the market or publish a compliance claim.

FAQ

Is RoHS part of the CE declaration, or separate?

RoHS 2011/65/EU is CE-marking legislation, so RoHS is one of the things the EU Declaration of Conformity asserts and it should be named on the declaration among the legislation applied. REACH 1907/2006 is not CE-marking legislation. It produces no CE mark and does not appear on the declaration, which is why REACH evidence has to be requested separately.

Can one RoHS certificate cover a whole product range?

Treat it as not covering the range. RoHS restrictions apply at the level of the homogeneous material, so a change of plating, polymer, seal or solder can change the answer even when the device looks identical. Ask for a report tied to the SKU and the revision you are buying, and check the sample described in the report against the part you received.

What REACH evidence should I ask for on an empty cartridge?

A REACH and SVHC statement that names the candidate list version it was checked against, plus contact-material declarations for every part in the vapour path: mouthpiece, seals, wick or ceramic core, and the tank. The candidate list is updated periodically, so a statement with no version and no date tells you very little.

Sources

• Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS) (recast), the official text on EUR-Lex.
• Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), the official text on EUR-Lex.
• Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) (recast), the official text on EUR-Lex.
• Regulation (EU) 2023/1542 concerning batteries and waste batteries, the official text on EUR-Lex.
• Regulation (EU) 2023/988 on general product safety (GPSR), the official text on EUR-Lex.

Trade guidance for B2B buyers, not legal advice. We sell empty hardware only; you are responsible for the fill and for finished-product compliance in your market.