RoHS and REACH Explained: Material Compliance for Festival Lighting

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:

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

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

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:

1. 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.

2. 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.

3. 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

Part 4: What This Means for Festival Lighting Projects

For LED Strings and Decorative Lights

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

Summary

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.

👉 Contact Us Today for product compliance information or to discuss your festival lighting project.