Estimated reading time: 7 minutes
Quick Answer
RoHS and REACH are two separate EU regulations that apply to festival lighting products sold in Europe. RoHS restricts ten specific hazardous substances (lead, mercury, cadmium, phthalates, etc.) in electrical equipment, with limits measured per homogeneous material. REACH is broader — it regulates chemicals across all products and requires communication when Substances of Very High Concern (SVHCs) are present above 0.1% by weight. For festival lighting, this means your LED strings, cables, connectors, and housings must all comply — and the documentation must be ready before shipment.
Introduction: Why Two Regulations Matter
Festival lighting — LED strings, decorative lights, pixel modules, and controllers — is electrical equipment. That means it falls under two overlapping EU regulatory frameworks that serve different purposes:
Regulation | What It Covers | Core Requirement |
|---|---|---|
RoHS | Hazardous substances in electrical/electronic equipment | Restricts ten specific substances |
REACH | All chemical substances in articles and products | Registration, communication, and restriction of SVHCs |
Many suppliers treat these as the same thing. They are not. RoHS is a specific restriction list for electronics. REACH is a broader chemical safety framework that applies to every article placed on the EU market. Both apply to festival lighting.
Part 1: RoHS — The Ten Restricted Substances
RoHS (Restriction of Hazardous Substances) is governed by Directive 2011/65/EU (RoHS 2) and amended by Directive (EU) 2015/863 (RoHS 3), which added four phthalates to the original six substances.
The Restricted Substances and Limits
Substance | Limit (by weight in homogeneous material) |
|---|---|
Lead (Pb) | 0.1% |
Mercury (Hg) | 0.1% |
Cadmium (Cd) | 0.01% |
Hexavalent Chromium (Cr VI) | 0.1% |
Polybrominated Biphenyls (PBB) | 0.1% |
Polybrominated Diphenyl Ethers (PBDE) | 0.1% |
Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% |
Butyl benzyl phthalate (BBP) | 0.1% |
Dibutyl phthalate (DBP) | 0.1% |
Diisobutyl phthalate (DIBP) | 0.1% |
Critical concept: The limit is measured per homogeneous material — meaning each individual material (solder, plastic housing, wire insulation, PCB) must independently meet the limit. A single product can have multiple homogeneous materials, and each must comply separately.
The Exemption for Copper Alloys
RoHS includes exemptions for certain applications where compliance is technically impractical. The most relevant for festival lighting is Exemption 6(c): copper alloys may contain up to 4% lead by weight.
This applies to connector pins, brass terminals, and similar copper alloy components. The exemption is why RoHS certificates often state "lead below 4% in copper alloy, covered by exemption 6(c)".
What This Means for Festival Lighting
Festival lighting products contain multiple homogeneous materials:
Solder — historically the highest-risk component for lead
PVC wire insulation — potential source of phthalates
Plastic housings and connectors — potential source of brominated flame retardants
PCB substrate — potential source of lead or cadmium
Each of these must be tested or declared separately. A single "RoHS compliant" statement for the finished product is not sufficient — the declaration must be backed by material-level evidence.
Part 2: REACH — The Broader Chemical Framework
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is governed by Regulation (EC) No 1907/2006. Unlike RoHS, REACH applies to all chemical substances — not just those in electronics.
REACH Has Three Main Lists
List | Purpose | Supplier Obligation |
|---|---|---|
Candidate List (SVHC) | Substances of Very High Concern | Communication if >0.1% w/w |
Annex XIV (Authorisation List) | Substances requiring authorisation | Cannot use without authorisation |
Annex XVII (Restriction List) | Substances with use restrictions | Must comply with specific conditions |
The Candidate List (SVHC)
The Candidate List is the most frequently relevant REACH list for festival lighting suppliers. It contains substances identified as carcinogenic, mutagenic, toxic to reproduction, persistent, bioaccumulative, or otherwise of equivalent concern.
Key obligations:
Article 33 Communication: If an article contains an SVHC above 0.1% weight by weight (w/w), the supplier must provide the recipient with sufficient information to allow safe use.
SCIP Database: Since January 2021, suppliers placing articles on the EU market containing Candidate List substances above 0.1% w/w must submit information to ECHA's SCIP database.
Notification: Article 7(2) requires notification to ECHA if the article contains an SVHC above 0.1% w/w and the quantity exceeds 1 tonne per year.
The list is dynamic. As of February 2026, the Candidate List contains 253 entries, with new substances added regularly. Suppliers must monitor updates and communicate changes immediately.
Annex XVII — Restriction List
Annex XVII contains substances with specific use restrictions. In January 2026, the European Commission proposed technical updates to Annex XVII to align with new hazard classifications under the CLP Regulation, adding substances including multi-walled carbon nanotubes, acetone oxime, and various other CMR (carcinogenic, mutagenic, or toxic to reproduction) substances.
For festival lighting, the most relevant restrictions typically involve:
Phthalates (already covered by RoHS, but also restricted under REACH)
Nickel (restricted in prolonged skin-contact articles)
Polycyclic aromatic hydrocarbons (PAHs) in rubber or plastic components
Part 3: RoHS vs REACH — A Practical Comparison
Aspect | RoHS | REACH |
|---|---|---|
Scope | Electrical/electronic equipment | All articles and chemicals |
Substance list | 10 specific substances | Candidate List (SVHC), Annex XIV, Annex XVII |
Limit basis | Per homogeneous material | Per article (0.1% w/w for SVHC) |
Primary obligation | Do not exceed limits | Communicate, notify, authorise, or restrict |
Documentation | Test reports, Declaration of Conformity | Article 33 information, SCIP submission |
Update frequency | Periodic amendments | Continuous — Candidate List updated regularly |
Part 4: What This Means for Festival Lighting Projects
For LED Strings and Decorative Lights
Component | RoHS Risk | REACH Risk |
|---|---|---|
Solder | Lead (exemption may apply) | Lead compounds |
PVC insulation | Phthalates (DEHP, DBP, BBP, DIBP) | Phthalates, SVHCs |
Plastic housing | PBB, PBDE | Brominated flame retardants, SVHCs |
Connectors | Lead in copper alloy (exemption 6c) | Nickel, SVHCs |
LED components | Cadmium, lead | Various |
Documentation Required Before Shipment
For festival lighting shipped to the EU, the minimum compliance file should include:
RoHS test reports from an accredited laboratory (ISO 17025), covering all homogeneous materials
RoHS Declaration of Conformity signed by the manufacturer or authorised representative
REACH Article 33 information if any SVHC is present above 0.1% w/w
SCIP submission confirmation if applicable
Technical documentation index linking models to reports and declarations
Part 5: Common Mistakes in Festival Lighting Compliance
Mistake | Why It Matters |
|---|---|
Treating RoHS and REACH as the same | They are different regulations with different obligations |
Relying on a single "compliant" statement | Material-level evidence is required for RoHS |
Ignoring the Candidate List updates | New SVHCs are added regularly; old declarations may be outdated |
Forgetting the SCIP database | Required since January 2021 for articles with SVHCs >0.1% |
Assuming exemptions apply automatically | Exemptions have specific conditions and expire |
Using expired test reports | Standards are updated; reports must reference current revisions |
Summary
Regulation | What It Requires | Key Action for Festival Lighting |
|---|---|---|
RoHS | 10 substances below limits per homogeneous material | Test all materials; obtain Declaration of Conformity |
REACH | SVHC communication, SCIP, restrictions | Monitor Candidate List; provide Article 33 info; submit SCIP |
Both | Documentation before shipment | Build compliance file with reports, declarations, and traceability |
Related Content
UL 588: What Seasonal and Holiday Lighting Suppliers Need to Know →
LED Festival Lighting Supplier Guide: Sourcing Wholesale Holiday and Event Decorative Lights →
LED Festival Lighting: How to Calculate Power Supply and Cable Length for Large Displays →
Need Help with Compliance Documentation?
We understand that RoHS and REACH compliance is a critical requirement for festival lighting projects in the EU market. Our products are designed and documented to meet these standards, and we can provide the compliance documentation your project requires.
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