REACH, RoHS, CE marking, WEEE: four bodies of European rules that bear directly on distributors and importers, even when they manufacture nothing. Taken one at a time, each boils down to a handful of documents to obtain from the supplier. Taken together, across a catalogue of several thousand product lines, they form a set of product attributes that must be collected, checked and redistributed. Here is what each text requires, and how to translate it into a data model.
REACH: tracing substances of very high concern
REACH is Regulation (EC) No 1907/2006 on chemical substances. A distributor does not register substances: its subject is Article 33, which requires any supplier of an article — a term that, under Article 3(33), covers distributors placing an article on the market — to pass on the information when a substance on the Candidate List is present above 0.1% by weight.
- To business customers — sufficient information to allow safe use, and at minimum the name of the substance, provided with the article.
- To consumers — the same information, free of charge, within 45 days of the request.
- To the SCIP database — Article 9(1)(i) of the Waste Framework Directive 2008/98/EC requires that same information to be submitted to the European Chemicals Agency from 5 January 2021.
Two nuances are worth the detour. First, retailers supplying articles directly and exclusively to consumers are not covered by the SCIP notification duty: also selling B2B, or placing an article on the market under your own brand, brings you back into scope. Second, in the “environmental omnibus” package of 10 December 2025 the Commission proposed to repeal the SCIP database on the grounds that it is little consulted, handing its role to the digital product passport. Until that text is adopted, the obligation stands — all the more reason to hold SVHC data yourself rather than treat it as a form to fill in on a portal.
The most underestimated practical point is the updating of the Candidate List: it grows in successive waves, and each addition can pull in product lines that were out of scope the day before. You therefore need to be able to replay a check across the whole catalogue at every update, which assumes composition and supplier declarations are stored as attributes, not as attachments nobody reopens.
RoHS: ten substances restricted in electrical equipment
Directive 2011/65/EU limits the concentration of ten substances in the homogeneous materials of electrical and electronic equipment (EEE). Annex II sets the values: 0.1% by weight for lead, mercury, hexavalent chromium, PBB, PBDE and the four phthalates added by Delegated Directive (EU) 2015/863 (DEHP, BBP, DBP, DIBP), and 0.01% for cadmium. The phthalate restriction has applied since 22 July 2019, and since 22 July 2021 for medical devices and monitoring and control instruments.
The scope is wide: Annex I lists eleven categories, the eleventh of which — “ other EEE not covered by any of the categories above” — closes the door on restrictive readings. On the obligations side, two articles concern you directly:
- Article 10 — the distributor acts with due care: it checks that the EEE bears the CE marking, that it is accompanied by the required documents in a language easily understood by users in the Member State where it is made available, and that the manufacturer and importer have applied their identification.
- Article 12 — for ten years after placing on the market, you must be able to identify, on request from market surveillance authorities, who supplied you an item of EEE and to whom you supplied it.
That ten-year traceability is a retention constraint: it rules out purging supplier data at the same time as the order lines.
CE marking: a declaration, not a label
CE marking is governed by Article 30 of Regulation (EC) No 765/2008: it may be affixed only by the manufacturer or its authorised representative, only on products for which harmonisation legislation provides for it, and it means the manufacturer takes responsibility for conformity. It is neither a quality mark nor a third-party certification. The accompanying document is the EU declaration of conformity, which a distributor must be able to produce on request from the authorities.
To this is added Article 4 of Regulation (EU) 2019/1020, applicable since 16 July 2021: for the products it covers, placing on the market presupposes that an economic operator established in the Union — an EU manufacturer, an importer, an authorised representative or a fulfilment service provider — is responsible for verifying that the declaration and technical documentation exist, keeping them available, and answering reasoned requests from the authorities. If you import yourself, that role is yours.
The substantive requirements come from the sectoral texts: Low Voltage Directive 2014/35/EU, electromagnetic compatibility 2014/30/EU, radio equipment 2014/53/EU. One date is worth noting: Machinery Directive 2006/42/EC is repealed with effect from 14 January 2027, when Regulation (EU) 2023/1230 becomes applicable. The technical data sheets and instructions for the machinery in your catalogue will change legal basis on that date.
WEEE: registration, eco-contribution and take-back
Directive 2012/19/EU (WEEE) organises the end of life of electrical and electronic equipment. The trap, for a distributor, is the definition in Article 3(1)(f): a “producer” is whoever resells under its own brand equipment produced by others, whoever imports into a Member State, and whoever sells at a distance into a Member State.
- Registration — Article 16 requires a national register of producers, in which distance sellers register in the Member State where they sell, directly or through an authorised representative.
- Take-back — Article 5(2) requires free one-for-one take-back on delivery of equivalent equipment and, for EEE sales areas of at least 400 m², take-back of very small WEEE (all external dimensions no more than 25 cm) with no obligation to buy.
- Symbol — the crossed-out wheeled bin of Annex IX, whose meaning must be explained to users (Article 14(2)).
In France, the unique identification number (IDU) issued by ADEME under Article L. 541-10-13 of the Environmental Code has been mandatory since 1 January 2022: Article R. 541-173 requires it to appear in the general terms and conditions of sale — or, failing that, in any other contractual document given to the buyer — and on the producer's website. ADEME states that failing to do so exposes the producer to an administrative fine of up to €30,000. These obligations combine with those of the AGEC law and the repairability index, which cover the same product families.
Translating these four texts into a data model
The four bodies of rules do not overlap, but they share a mechanism: data obtained from the supplier, stored by product reference, checked before publication, redistributed to every channel and kept for a long time. Each therefore comes down to structured attributes.
| Requirement | PIM attribute | Where the data comes from |
|---|---|---|
| REACH Art. 33 — SVHC > 0.1% by weight | reach_svhc_presence, reach_svhc_names, reach_declaration_date | Supplier declaration, safety data sheet |
| SCIP notification (Directive 2008/98/EC) | scip_number, scip_status | ECHA submission receipt, or the number passed on by the supplier |
| RoHS — Annex II, homogeneous materials | rohs_compliant, rohs_exemptions, rohs_annex_i_category | Manufacturer's declaration of conformity |
| CE marking and EU declaration of conformity | ce_required, doc_reference, doc_document, applicable_texts | Manufacturer's technical file, mandate of representation |
| Regulation (EU) 2019/1020 Art. 4 — responsible operator | eu_operator_name, eu_operator_address, eu_operator_email | Your own entity if you import, otherwise the manufacturer's mandate |
| WEEE — registration and IDU | weee_category, weee_idu, eco_contribution_amount | Producer responsibility organisation (ecosystem, Ecologic…), ADEME register |
| RoHS Art. 12 — ten-year traceability | supplier_id, first_made_available_date | ERP and orders |
Make attributes mandatory by family, not by product
Not every product line falls under the same texts: an HDMI cable falls under RoHS and WEEE, a garment under neither. The right granularity is therefore the family: attach the applicable attribute set to it, mark those attributes required at that level, and let the model propagate the rule to new product lines. Conditional rules do the rest — eu_operator_name only becomes mandatory when the manufacturer is outside the EU.
Check before publication, not after a complaint
A completeness score calculated per family on the required attributes makes it possible to block publication of an incomplete product page. Three checks are worth automating: the presence of the declaration of conformity, the expiry date of documents, and consistency between the country of the storefront and the language of the instructions.
Collect the data at the catalogue entrance
These attributes cannot be inferred; they have to be asked for. Build them into the supplier onboarding questionnaire alongside purchase price and EAN, and refuse to open a product line until they are filled in. When the supplier sends files rather than a form, automated mapping of its feeds avoids re-keying. That is the logic of the Compliance module in Pixee PIM, which brings together REACH, RoHS, CE, WEEE and EPREL attributes.
What you risk without document management
The consequences stack up: refusal to make the product available, withdrawal or recall at the distributor's expense, national penalties — Article 22 of the WEEE Directive leaves it to Member States to set penalties that are “effective, proportionate and dissuasive”. The day-to-day cost, meanwhile, is measured in hours spent tracking down a document sent two years ago.
Frequently asked questions
I am a distributor, not a manufacturer: do these texts really apply to me?
Yes, but not with the same content. RoHS imposes a verification duty (Article 10) and a traceability duty (Article 12), not laboratory testing. REACH covers you as a supplier of an article within the meaning of Article 3(33). The WEEE Directive can reclassify you outright as a “producer” if you import or sell at a distance into a Member State. You do not produce the data: you collect it, keep it and redistribute it.
What should I do when a supplier will not provide its declaration?
Treat it as blocking missing data. Article 10 of the RoHS Directive is clear: where a distributor has reason to believe that an item of EEE is not compliant, it does not make it available until it is. The practical lever is onboarding — making compliance attributes mandatory when a product line is opened changes the conversation far more effectively than chasing after the fact.
Does the work have to be redone at every Candidate List update?
It has to be replayable, which is not the same thing. If composition and declarations are stored as attributes per product reference, an addition to the Candidate List triggers a query on the catalogue and a re-collection targeted at the families concerned. If they live in PDFs, everything has to be reopened.
Is a PIM enough to make me compliant?
No, and it does not replace legal analysis: only the official text is authoritative, and the timetables move — the 10 December 2025 proposal to repeal the SCIP database is a good example. A PIM handles the data side: centralising attributes, making them mandatory by family, checking completeness before publication, distributing to every channel, keeping the history for as long as the texts require. Decisions about placing on the market and withdrawal remain yours.
Manage REACH, RoHS, CE and WEEE compliance in your PIM
Compliance attributes per family, expiry alerts, pre-publication checks and document export for audits.
See the Compliance module