RoHS, REACH, and PFAS: What Compliance Documents Does an OEM Need From Its Display and Embedded Suppliers?

To ship a product into regulated markets, an OEM needs every component supplier to document what its parts contain. For display and embedded components that means RoHS and REACH compliance for the European Union, Proposition 65 and PFAS information, and a conflict minerals declaration. At FORTEC US, RoHS, REACH, Conflict Minerals, Proposition 65, and PFAS declarations are available on request, and because we engage at specification, not at purchase order, compliance is part of the design conversation from the start.

What is the difference between RoHS and REACH compliance?

RoHS restricts ten named hazardous substances in electrical and electronic equipment, while REACH regulates chemicals in general and requires suppliers to tell customers when a product contains a Substance of Very High Concern (SVHC) above 0.1% by weight. Both are European Union rules, and RoHS compliance is mandatory for selling electronic products in the EU.

The RoHS directive sets maximum concentrations for lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates: BBP, DEHP, DBP, and DIBP. The limit is 0.1% for nine of them and 0.01% for cadmium. RoHS-II took effect on January 2, 2013, and RoHS-III, which added the four phthalates, on July 22, 2019. Since RoHS-II, CE compliance declarations must include the directive. Our RoHS page carries our RoHS statement for download, and our post on RoHS compliance and the RoHS directive in electronics manufacturing covers the directive in more depth.

REACH, Regulation (EC) No. 1907/2006, came into force on June 1, 2007. The European Chemicals Agency (ECHA) has published a list of SVHCs, and under Article 33 every manufacturer and importer of a product containing more than 0.1% by weight of any SVHC must inform its customers, even when the substance is not released under normal conditions of use. According to our present knowledge, our products do not contain SVHCs above that threshold, as our REACH statement confirms. Our post on achieving REACH compliance and chemical safety explains registration, evaluation, authorization, and restriction.

What do Proposition 65 and PFAS mean for electronics?

Proposition 65, California’s Safe Drinking Water and Toxic Enforcement Act of 1986, means a product containing listed substances may need to carry a warning. PFAS, or per- and polyfluoroalkyl substances, are a family of chemicals that regulation is still catching up with. Both depend on substance information from deep in the supply chain, and suppliers do not always provide it in full.

Our statement on California Proposition 65 and PFAS says so plainly. We do not claim that every product is free of Proposition 65-listed substances or PFAS, and products may carry a Proposition 65 warning where appropriate. When a design has to meet a specific Proposition 65 or PFAS requirement, raise it at specification, so the parts are chosen with that requirement in view.

What is a conflict minerals declaration?

A conflict minerals declaration states a supplier’s position on the rules for conflict minerals under the US Dodd-Frank Act, which concern where minerals used in electronic components are sourced. Ours is available on request with our other declarations.

Is ISO 9001 a RoHS or REACH compliance certificate?

No. ISO 9001:2015 certifies a quality management system, not the substances in a product. FORTEC US is an ISO 9001:2015 Registered Company, Certificate No. US3606, and substance compliance is documented separately, through the declarations above.

Why does compliance belong at the design stage?

Because the declaration for a finished assembly can only be as complete as the information behind every part in it. A display assembly brings together the panel, optical bonding, touchscreen, cover glass, mechanical enclosure, seals, cables, and connectors, and the embedded computer and power supply behind it add parts of their own. Settling the documentation while parts are still being chosen is simpler than chasing it once the design is frozen.

We are not a distributor. Design and development, VacuBond® optical bonding, touch integration, and production all happen at our facility in Ronkonkoma, New York, under one ISO 9001:2015-registered quality system. Display, embedded, and power expertise sit under one roof at FORTEC, so one engineering team is accountable for the whole assembly, and the engineers who specify the system are the same team that answers when something changes.

How FORTEC US supports compliance on your next design

All five declarations are available on request, and our RoHS and REACH statements can be downloaded from their pages. The same list appears on our Medical, Industrial, and Defense sector pages. Regulations keep moving, PFAS especially, so we monitor regulatory changes and communicate openly with customers about the information available to us.

Tell us where the product has to ship and what your compliance file needs, and we will take it from there. We recommend the right combination of display, computer, and power, handle the integration and the sourcing through the FORTEC Group supply network, and stay with the project from first samples to series production. When a part receives an end-of-life notice, we tell you early and plan with you: a last-time buy to cover remaining builds, or qualifying a replacement before supply runs out. Our obsolescence management page explains how, and our guide on how to plan for component obsolescence before it becomes a problem covers the planning side.