The REACH Regulation (EC 1907/2006) governs the registration, evaluation, authorization, and restriction of chemical substances in the European Union. Luminaires, as complex electrical products, contain various materials—plastics, metals, electronic components, coatings, and adhesives—that may include restricted or hazardous chemicals. Compliance with REACH is mandatory for any lighting product placed on the EU market.
First, manufacturers must identify Substances of Very High Concern (SVHC) in luminaire components. REACH requires notification if an SVHC exceeds 0.1% weight by weight (w/w) in an article. Common SVHCs in luminaires include lead, cadmium, phthalates in PVC cables, brominated flame retardants, and certain stabilizers. Even if a substance is used in a small internal part, the entire luminaire is considered as an article, and the 0.1% threshold applies to each component.
Second, the authorization and restriction lists under REACH Annex XVII prohibit specific substances in certain applications. For example, cadmium in paints and stabilizers, and lead in solders are restricted. Lighting products must also align with the RoHS Directive (2011/65/EU), which overlaps with REACH but focuses on electrical and electronic equipment. RoHS limits lead, mercury, cadmium, hexavalent chromium, PBBs, and PBDEs.
Third, manufacturers must ensure that their suppliers provide REACH-compliant materials. This often requires declaration forms, test reports, and analytical data. A strong supply chain communication system is essential to track chemical content down to the raw material level.
Finally, non-compliance can result in market withdrawal, fines, and reputational damage. Proactive steps include maintaining a dynamic SVHC inventory, updating technical documentation, and registering substances in the REACH database when import volume exceeds one tonne per year. In summary, luminaire manufacturers must integrate REACH compliance into product design, supplier management, and documentation processes to ensure legal access to the European lighting market.