Three separate regulatory regimes govern the materials in every PCB assembly, and a B2B electronics buyer's bill of materials usually has to satisfy all three at once. RoHS restricts specific hazardous substances in the finished product. REACH manages chemical substances across the EU market, including a growing list of substances of very high concern (SVHC). Conflict Minerals rules (U.S. Dodd-Frank Section 1502 and the EU Conflict Minerals Regulation) govern the responsible sourcing of tin, tungsten, tantalum, and gold (3TG). They overlap in scope but differ in mechanism, geography, and where the legal obligation lands. This primer explains what each actually requires, who owns the obligation between the OEM and the contract manufacturer (CM), and how to build a materials-declaration process that survives a customer audit.

The audience is the procurement lead, the compliance manager, and the design engineer who has to answer "is this board RoHS/REACH/conflict-minerals compliant?" on a customer questionnaire. Each section maps to a specific declaration your customers will eventually ask for.

Why materials compliance is three problems, not one

It's tempting to treat "RoHS/REACH/conflict minerals" as a single compliance checkbox, but they're structurally different. RoHS is a product regulation — it restricts what can be in the finished assembly. REACH is a chemical regulation — it governs substances and requires communication down the supply chain when SVHCs are present above thresholds. Conflict minerals rules are a sourcing-transparency regulation — they don't ban materials but require due-diligence reporting on the origin of specific metals. The obligations land differently: RoHS compliance is largely designed-in at component selection, REACH compliance is an ongoing substance-tracking obligation, and conflict-minerals compliance is a supply-chain-disclosure obligation. A CM helps with all three but owns none of them outright — the legal manufacturer (usually the OEM) carries ultimate responsibility.

The 10-point materials-compliance framework

1. What does RoHS actually restrict, and which version applies?

RoHS (Restriction of Hazardous Substances) — the current EU directive is RoHS 3 / Directive (EU) 2015/863 — restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, PBB and PBDE flame retardants, and four phthalates (DEHP, BBP, DBP, DIBP). The limits are 0.1% by weight in any homogeneous material (0.01% for cadmium). "Homogeneous material" is the key concept — it's not the whole board, it's each individual material that can't be mechanically separated further, so a solder joint, an IC's lead finish, and a connector's plating are each evaluated independently. For PCBA, RoHS compliance is achieved primarily through component and solder selection (SAC lead-free alloys, RoHS-compliant component finishes) at design time.

2. Is "RoHS compliant" the same everywhere, or does each region have its own version?

Different regions, similar-but-not-identical rules. EU RoHS is the reference standard. China RoHS (the "China RoHS 2" / SJ/T 11364) requires marking and disclosure but historically had different scope and exemptions. California Proposition 65 overlaps on some substances with its own warning requirements. Other markets (UK post-Brexit, various Asian markets) have adopted EU-RoHS-aligned rules with local variations. For a B2B PCBA buyer selling globally, the practical approach is to design to EU RoHS 3 (the strictest broadly applicable standard) and verify the specific regional requirements for each target market. Ask whether your declarations cover the specific markets you ship to, not just "RoHS" generically.

3. What does REACH require that RoHS doesn't?

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals, EU Regulation 1907/2006) is far broader than RoHS. The relevant piece for PCBA is the SVHC Candidate List — a list of substances of very high concern (currently 240+ substances, updated twice a year) maintained by the European Chemicals Agency (ECHA). If any article in your product contains an SVHC above 0.1% by weight, you have a communication obligation down the supply chain and to consumers on request, plus potential SCIP-database notification requirements. Unlike RoHS's fixed 10 substances, the REACH SVHC list grows continuously — meaning a board that was REACH-compliant last year can become non-compliant when a new SVHC is added that's present in one of its components. REACH is an ongoing tracking obligation, not a one-time design check.

4. What's the SCIP database and does my PCBA trigger it?

SCIP (Substances of Concern In articles, as such or in complex objects/Products) is an ECHA database that requires companies placing articles containing SVHCs (above 0.1%) on the EU market to submit information about those substances. If your PCBA contains an SVHC above threshold and is sold into the EU, a SCIP notification is generally required. The practical challenge: determining whether any component contains an SVHC requires full-material-declaration data from your component suppliers, which is exactly the data that's hardest to get for legacy or commodity parts. Ask your CM and component distributors whether they can provide full material declarations (FMD) or IPC-1752A Class D declarations that surface SVHC content.

5. What are conflict minerals (3TG) and what does the rule actually require?

Conflict minerals are tin, tungsten, tantalum, and gold (collectively "3TG") — metals whose mining has historically funded armed conflict in the Democratic Republic of Congo and adjoining countries. U.S. Dodd-Frank Section 1502 requires SEC-reporting companies to conduct supply-chain due diligence and disclose whether their products contain 3TG sourced from conflict-affected regions. The EU Conflict Minerals Regulation (2017/821) imposes due-diligence obligations on importers. Critically, the rules don't ban 3TG — every PCBA contains tin (solder) and gold (plating) — they require transparency about sourcing. The compliance mechanism is the smelter-level audit: tracing each 3TG metal back to a smelter and confirming the smelter is conformant with the Responsible Minerals Initiative (RMI) program.

6. How do I actually collect conflict-minerals data for my BOM?

The industry-standard tool is the Responsible Minerals Initiative (RMI) Conflict Minerals Reporting Template (CMRT) — a standardized Excel form that cascades down the supply chain. As an OEM, you send the CMRT to your suppliers (including your CM); they populate it with smelter data from their suppliers, and the data aggregates up. The CMRT identifies the smelters in your supply chain and their RMI-conformance status. The practical reality: response rates and data quality vary widely, especially for commodity components. A mature compliance process tracks CMRT response rates, follows up on gaps, and maintains a current smelter list. Ask your CM whether they participate in CMRT cascades and can provide a populated template for the components they source.

7. Where does the legal obligation actually land — OEM or contract manufacturer?

The OEM, as the legal manufacturer placing the product on the market, carries ultimate compliance responsibility for RoHS, REACH, and (for SEC-reporting OEMs) conflict-minerals disclosure. The CM's role is to supply the data and build to RoHS-compliant material specifications — but the CM doesn't typically issue the RoHS Declaration of Conformity or file the conflict-minerals disclosure; the OEM does. This division matters because OEMs sometimes assume "we use a compliant CM, so we're compliant," which is incomplete. The CM provides material declarations, builds with compliant materials, and supports CMRT cascades; the OEM aggregates that data, issues declarations, and carries the legal liability. A good CM makes this division explicit in the quality agreement.

8. What documentation should my CM provide to support materials compliance?

A compliance-capable CM should be able to provide: (a) RoHS Certificates of Compliance for the assembly, tied to the specific BOM revision; (b) material declarations for components (IPC-1752A Class C for RoHS, Class D for full material declaration including REACH SVHC); (c) populated CMRT templates for the 3TG content in components they source; (d) solder and process-material data sheets confirming RoHS-compliant alloys and fluxes; and (e) traceability linking each declaration to the specific lot built. Ask: "For a representative BOM, can you produce the RoHS CoC, component material declarations, and a CMRT within 5 business days?" A CM that produces this readily has a real materials-compliance process; one that scrambles is relying on you to backfill the data.

9. How do I handle materials compliance when a component goes obsolete and I have to substitute?

Component substitution is the most common way a previously-compliant board drifts out of compliance. When an EOL part is replaced with an alternate, the alternate's material declarations, RoHS status, and conflict-minerals smelter data are all potentially different. A disciplined process re-runs the compliance check on every component substitution: verify the alternate's RoHS compliance, check whether it introduces any SVHCs above threshold (REACH), and update the CMRT smelter list if the 3TG sourcing changes. This is where configuration management (the same discipline AS9100D requires) intersects with materials compliance — every BOM revision should carry an updated compliance status. Ask your CM how component substitutions flow through their compliance-verification process.

10. Does using a U.S. contract manufacturer change my materials-compliance obligations?

The obligations follow the market you sell into, not where the board is built. A board built in the U.S. but sold into the EU must still satisfy EU RoHS, REACH, and (for EU importers) the EU Conflict Minerals Regulation. What a U.S. CM can change is the quality and accessibility of the compliance data: domestic CMs with mature quality systems (AS9100D, ISO 13485) typically maintain better materials-declaration traceability and respond faster to compliance-data requests than offshore CMs where the data cascade is longer and slower. The compliance obligation is the same; the ease of satisfying it with documented, traceable data is often better with a domestic CM running a configuration-managed BOM.

Common materials-compliance mistakes

  • Treating RoHS, REACH, and conflict minerals as one checkbox. They're three different regimes with different mechanisms, geographies, and obligations. A single "compliant" claim usually means only one was actually checked.
  • Assuming "compliant CM = compliant product." The OEM carries ultimate legal responsibility and issues the declarations. The CM supplies data; it doesn't absorb the OEM's liability.
  • Checking REACH once and never re-checking. The SVHC list grows twice a year. A compliant board can become non-compliant when a new SVHC is added that's present in an existing component.
  • Skipping the compliance re-check on component substitutions. An EOL substitution is the most common path to silent non-compliance. Every BOM revision needs a fresh compliance status.
  • Accepting CMRT templates without checking smelter conformance. A populated CMRT with non-conformant smelters isn't compliance — it's documented non-compliance.
  • Not collecting full material declarations for SCIP. Without component-level FMD data, you can't determine SCIP-notification obligations for SVHC-containing articles.

How i-TECH e-Services supports materials compliance

i-TECH e-Services builds to RoHS-compliant material specifications by default and maintains the configuration-managed BOM traceability that materials-compliance data depends on. Practical implications for OEMs managing RoHS / REACH / conflict-minerals obligations:

  • RoHS-compliant materials and processes as the default — SAC lead-free solder alloys, RoHS-compliant component finishes, and compliant process consumables, with Certificates of Compliance available tied to the specific BOM revision.
  • Component material declaration support — we cascade material-declaration and CMRT requests through our distribution channels and provide the aggregated data for the components we source.
  • Configuration-managed BOMs aligned to AS9100D quality discipline, so every component substitution flows through a documented change process where compliance status can be re-verified.
  • Full lot traceability linking each build to the specific component lots and their declarations — the foundation any materials-compliance audit depends on.
  • Clear OEM/CM responsibility division documented in the quality agreement, so it's explicit which declarations the OEM issues and which data i-TECH supplies.
  • U.S.-based, configuration-managed operations — see our manufacturing capabilities — that typically make compliance-data requests faster and more traceable than offshore alternatives.

If you're building a materials-compliance process for a new PCBA program or responding to a customer compliance questionnaire, our team can walk through what declarations we provide and how they integrate with your RoHS Declaration of Conformity and conflict-minerals reporting. Request a quote with your BOM and target markets, and we'll outline the compliance-data package in the response.

Bottom line

RoHS, REACH, and conflict-minerals compliance are three distinct obligations that every B2B PCBA program has to manage, usually simultaneously, with the legal responsibility landing on the OEM and the supporting data flowing from the contract manufacturer. The OEMs who manage this well treat it as an ongoing configuration-managed process — re-checking REACH as the SVHC list grows, re-verifying compliance on every component substitution, and collecting traceable declaration data from a CM whose quality system actually maintains it. Choose a CM that produces the RoHS CoC, material declarations, and CMRT on request, and build the materials-compliance check into your BOM-change process. The alternative is discovering a compliance gap during a customer audit — the worst possible time.