Component Identified as RoHS Compliant with an Exemption for Lead

When electronic components are identified as being RoHS compliant but have an exemption for lead, can that component be considered REACH 235 compliant? I ask this question because I have been seeing some REACH certificates for components that are RoHS complaint but carry exemptions for Lead.

DXP - the operator of the IMDS does offer a REACH Reports service and I have found then economical

You can find them on the IMDS website

feel free to reach out to me directly - I am pretty easy to find on the web and am based in USA

I have a cert that says REACH compliant at the same time the RoHS cert says compliant with an exemption for lead. Is it possible to have a component that is RoHS compliant with an exemption for lead and be considered REACH compliant?

REACH doesn't apply to individual components.

A component that is "RoHS compliant but have an exemption for lead" is not RoHS compliant. A product may contain components with levels above permitted maximum levels if the specific application falls under an exemption in either or Article 2(4) or Annex III

Some companies require their vendors to meet REACH compliance to export products to the European Union. PCBA manufacturers are required to determine REACH compliance of their electronic components that are purchased and used to assembly product. If the REACH certificates provided by the electronic component manufacturer does not apply to individual components then how would you determine whether or not the electronic components that were used to assemble PCBA's meets the current REACH requirements? Also, manufacturers are providing RoHS certificates stating RoHS compliant with exemptions for lead (7 (c) - 1 or 7a. Are you saying that though the manufacturer has an approved exemption for lead to be above the permitted maximum level the certificate the manufacturer provides should not state RoHS compliant and should be classified as being not RoHS compliant? How would you go about determining whether or not the printed circuit board you populated with electronic components, purchased from various distributors/manufacturers meets REACH and RoHS compliance to export to the European Union?

REACH doesn't apply to individual products as there's a minimum weight per year required for registration.

Many companies require vendors to supply compliance certificates against all sorts of requirements - unfortunately not all companies product fully correct lists of requirements

Regarding " RoHS certificates stating RoHS compliant with exemptions for lead (7 (c) - 1 or 7a." - that means that the component contains lead above the permitted level but it is designed for use in products that fall under the exemption so it can be sold.
Don't forget, RoHS applies to "each and every component within a piece of Electrical and Electronic Equipment" - it doesn't apply to components themselves.

If your product (EEE) does not fall under an exemption you are not permitted to use a component that exceeds the permitted level of any of hte 9 listed substances.

Because REACH doesn't apply to individual products and there's a minimum weight per year required for registration, when a manufacturer is under the minimum weight per year requirement and are not required to register then that manufacturer can state their product is REACH compliant? Also, when a product is identified as being not REACH compliant and you are required to report the substance name and weight, then you would report the total weight for the year that exceeded the minimum weight?

If you're under the registration requirements you aren't "REACH compliant" but are "out of scope of REACH"

Ok, that makes sense. My last questions is, when I see on a distributors web site for a specific part number component "REACH Unaffected" does that mean that the manufacturer for that part number component is out of scope for REACH? I am not too sure what REACH unaffected means, but am guessing it means the part number is identified as not being REACH compliant. Lastly, I do thank you very much for your feedback!

I'm not sure what "REACH Unaffected" means - you might need to ask them

you're welcome