Projector RoHS & REACH Compliance: Substance Restrictions Explained

RoHS and REACH compliance are two of the most misunderstood regulations in the projector industry, but both are mandatory for any electronic product sold in the EU (and increasingly, in other markets that follow EU standards). For OEM/ODM buyers, getting these wrong leads to customs seizures, retailer delistings, and brand-damaging recalls. This guide explains what each regulation restricts, how testing works, and how to manage compliance with your Chinese factory.

RoHS vs REACH: What's the Difference?

RoHS and REACH are often confused but regulate different things:

Regulation	Scope	What It Restricts
RoHS (2011/65/EU)	Electrical and electronic equipment	10 specific substances in homogeneous materials
REACH (EC 1907/2006)	All chemical substances	All chemicals; specific focus on SVHCs >0.1% w/w

In simple terms:

• RoHS = "your product must not contain more than X ppm of these 10 specific substances"
• REACH = "if your product contains any SVHC above 0.1% by weight, you must disclose it"

Both apply to projectors. Both require testing and documentation. Both can result in mandatory recall if violated.

The 10 RoHS-Restricted Substances

For a reference platform that ships with Google TV pre-licensed and full-sealed optics, see our GP95-GTV 400 ANSI Full-Sealed Smart Projector—a production-validated starting point for OEM/ODM partners targeting the certification-heavy Android TV market.

Buyers looking for a turnkey smart OS reference should evaluate the GP95-GTV 400 ANSI Full-Sealed Smart Projector with Google TV Built-In. Google TV is licensed and pre-integrated, eliminating months of middleware work for ODM projects.

On the high-brightness side, the GP98 12400 Lumens Smart Projector for Meeting Rooms is our flagship reference platform for ODM partners—laser-phosphor light source with a sealed optical block.

RoHS restricts the following substances in homogeneous materials:

Substance	RoHS Limit (ppm)	Common Sources in Projectors
Lead (Pb)	1,000	Solder, leaded glass in older optics, certain pigments
Mercury (Hg)	1,000	CCFL backlights (rare in modern projectors)
Cadmium (Cd)	100	Cadmium plating (rare in modern projectors)
Hexavalent chromium (Cr6+)	1,000	Metal surface treatments
Polybrominated biphenyls (PBB)	1,000	Older flame retardants in plastics
Polybrominated diphenyl ethers (PBDE)	1,000	Older flame retardants in plastics
Bis(2-ethylhexyl) phthalate (DEHP)	1,000	PVC cable insulation
Butyl benzyl phthalate (BBP)	1,000	PVC cable insulation
Dibutyl phthalate (DBP)	1,000	PVC cable insulation
Diisobutyl phthalate (DIBP)	1,000	PVC cable insulation

The last 4 phthalates were added in 2015 by Directive (EU) 2015/863. They are common in flexible PVC used for cables and wire insulation.

REACH SVHCs

REACH is a moving target. The European Chemicals Agency (ECHA) maintains a "Candidate List" of Substances of Very High Concern (SVHCs). As of 2026, the list contains 240+ substances. New substances are added twice per year (typically January and July).

If your projector contains any SVHC above 0.1% w/w in any homogeneous material, you must:

• Notify ECHA within 6 months of inclusion in the Candidate List
• Provide safety data sheet (SDS) to downstream recipients
• Disclose the substance to consumers upon request (free of charge, within 45 days)
• Include SCIP notification in the EU SCIP database

Common SVHCs in projectors:

• Phthalates (DEHP, DBP, BBP, DIBP — also RoHS restricted)
• Lead compounds (in solder, certain pigments — also RoHS restricted)
• Brominated flame retardants (in PCBs and plastic housings — also RoHS restricted)
• Various pigments (cadmium pigments in colored plastics)

Testing Requirements

RoHS Testing

RoHS testing is conducted on homogeneous materials (a material that cannot be mechanically separated into different materials). Examples:

• The plastic housing = one homogeneous material
• Each PCB = one homogeneous material (solder is part of the PCB)
• Each cable jacket = one homogeneous material
• Each metal part (with surface treatment) = one homogeneous material
• Each LED module = potentially multiple homogeneous materials (housing, lens, solder, LED chip)

Typical RoHS testing program for a projector:

Component	Tests Required	Cost per Sample
Plastic housing	XRF screening + ICP-MS verification	$300–$500
PCBA	XRF screening + ICP-MS for solder	$400–$700
Cables	XRF screening + phthalate testing	$300–$600
Metal parts	XRF screening	$200–$400
LED module	XRF + ICP-MS	$400–$700
Speaker assembly	XRF screening	$300–$500
Total typical cost	10–15 samples	$4,000–$9,000

XRF (X-ray fluorescence) is a fast, non-destructive screening tool. Positive results are confirmed by ICP-MS (inductively coupled plasma mass spectrometry), which is more accurate but destructive.

REACH Testing

REACH testing is more complex because SVHCs change over time. There are two approaches:

1. Full SVHC screen — test for all 240+ SVHCs. Expensive ($8,000–$20,000) and slow.
2. Targeted SVHC screen — test for substances likely to be present based on BOM. Faster ($1,500–$4,000).

Most OEM/ODM buyers use the targeted approach, supported by material declarations from component suppliers.

Exemptions

RoHS allows certain exemptions for specific applications where the substance cannot be feasibly substituted. Common projector-relevant exemptions:

Exemption	Substance	Application
6(a)	Lead	Steel alloy for machining, galvanized steel
6(b)	Lead	Aluminum alloy for machining
6(c)	Lead	Copper alloy (brass) containing up to 4% lead
7(a)	Lead	High-temperature solders (in some glass-to-metal seals)
7(c)-I	Lead	Dielectric ceramic in capacitors
8(b)	Cadmium	Cadmium in electrical contacts

Exemptions expire on a schedule set by the EU. The European Commission periodically reviews whether exemptions remain justified. For new product designs, we recommend avoiding exempted substances where feasible.

Documentation Requirements

For RoHS

• Test reports from an ISO 17025-accredited lab
• Material declarations from component suppliers (many component makers provide RoHS compliance statements)
• Technical file maintained for 10 years
• CE Declaration of Conformity citing RoHS Directive 2011/65/EU

For REACH

• Safety Data Sheets (SDS) for any SVHC-containing materials
• SCIP database notification (mandatory since January 2021)
• Communication up and down the supply chain — suppliers notify you, you notify your customers
• Consumer disclosure within 45 days upon request, free of charge

Common RoHS/REACH Pitfalls

Five mistakes:

1. Treating XRF as definitive — XRF is a screen. Positive results must be confirmed by ICP-MS.
2. Skipping REACH because "RoHS is enough" — RoHS covers 10 substances. REACH covers 240+. Different compliance.
3. Missing SCIP database notification — mandatory since 2021. Penalties for non-notification are steep.
4. Outdated SVHC list — REACH SVHC list grows twice per year. Test reports from 2024 may not cover 2026 SVHCs.
5. Cable phthalates — the 4 phthalates added in 2015 are often missed by factories still using legacy cable suppliers.

How to Manage RoHS/REACH with Your Factory

Best practices:

1. Request the factory's RoHS test reports — most factories maintain a library
2. Specify "RoHS + REACH SVHC compliant" in your RFQ — be explicit
3. Verify the lab is ISO 17025 accredited — request the certificate
4. Request material declarations from component suppliers — ask for the chain of custody
5. Bundle RoHS/REACH testing with CE/FCC — combined programs save 15–25%
6. Maintain your own copy of all compliance docs — do not rely solely on the factory
7. Update testing every 2–3 years — regulations change; re-test periodically

Cost Summary

For a new SKU sold globally:

Activity	Cost (USD)	Lead Time
RoHS testing (10 substances, full product)	$4,000–$9,000	2–3 weeks
REACH SVHC targeted screen	$1,500–$4,000	1–2 weeks
SCIP database notification setup	$500–$2,000	1 week
Annual SVHC list update	$1,000–$2,500	1 week
Total per new SKU	$7,000–$17,500	4–8 weeks

For EU + UK + US + Canada markets, RoHS testing can typically be reused (since RoHS-style substance restrictions are common globally). REACH is EU-specific but often adopted by other markets voluntarily.

Conclusion and Next Step

RoHS and REACH compliance is a regulatory necessity, not a nice-to-have. The cost ($7,000–$17,500 per new SKU) is manageable, the timeline is predictable, and the documentation requirements are clear once you understand them.

💼 Need RoHS/REACH documentation for our projectors?

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We maintain current RoHS test reports for all catalog SKUs and provide REACH SVHC statements and SCIP database notifications on request. Our team will supply compliance documentation within 24 hours.

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