RoHS and REACH set the chemical content rules for products entering the EU market. A contract supplier producing machined metal parts is not the direct addressee of these regulations; the addressee is the manufacturer that assembles the part into a product and places it on the market. However, the manufacturer proves compliance with declarations obtained from its supply chain; therefore requesting a correctly worded, verifiable declaration from the Turkish supplier has become standard. Complementing our material certificate and surface treatment articles, this article explains the practical aspects of the two regulations for metal parts.
RoHS: Scope and Restricted Substances
The RoHS Directive (2011/65/EU, "RoHS 2", plus four phthalates added by 2015/863) restricts the use of certain hazardous substances in electrical and electronic equipment (EEE). The 10 restricted substances and their thresholds (by weight in homogeneous material): lead 0.1%, mercury 0.1%, cadmium 0.01%, chromium (VI) 0.1%, PBB 0.1%, PBDE 0.1%, DEHP, BBP, DBP and DIBP each 0.1%. Critical point: RoHS concerns only parts of products within the scope of EEE; an agricultural machinery shaft or a hydraulic block is not within RoHS scope. The buyer should state that the part will go into a product within RoHS scope.
Lead Exemptions in Metal Alloys
The subject the machining industry most often encounters is lead. Because it improves machinability, lead is present in brass (CuZn39Pb3: 2.5–3.5% Pb), free-cutting steel (11SMnPb30: 0.2–0.35% Pb) and some aluminium alloys. RoHS Annex III grants exemptions for these alloys:
| Exemption | Scope | Limit |
|---|---|---|
| 6(a) | Lead as an alloying element in steel for machining purposes and in galvanised steel | Up to 0.35% by weight |
| 6(b) | Lead as an alloying element in aluminium | Up to 0.4% (sub-types 6(b)-I, 6(b)-II) |
| 6(c) | Lead in copper alloys | Up to 4% by weight |
These exemptions are time-limited and are periodically renewed or narrowed by the Commission; validity dates differ by category. The declaration must clearly state which exemption is relied on: "CuZn39Pb3 part is compliant under RoHS Annex III exemption 6(c)." If the buyer wants compliance without exemption, a lead-free alternative (CuZn21Si3P/ECOBRASS, CuZn42, lead-free free-cutting steel 11SMn30/11SMn37) must be selected and the machining cost difference taken into account. Alloy options are explained in our brass article.
RoHS in Coatings
Hexavalent chromium (Cr VI) is found in old-style yellow-passivated zinc coatings and chromium-VI-based conversion coatings; it is prohibited under RoHS. Today zinc coatings are made with Cr(III) passivation, and aluminium conversion coatings with Cr(III) or chromium-free alternatives. Hard chrome plating contains metallic chromium (Cr 0) and is outside the RoHS restriction; however, because the plating bath contains Cr(VI), it is subject to the REACH authorisation regime (below). Cadmium plating is in practice not used outside aerospace. The buyer should explicitly request the wording "Cr(VI)-free" in the coating specification.
REACH: SVHC, the 0.1% Threshold and Notification
The REACH Regulation (1907/2006) applies to all articles; there is no sector restriction. Two obligations stand out for machined metal parts:
- Article 33 – Duty to communicate information: If an article contains an SVHC (Substance of Very High Concern) on the Candidate List above 0.1% by weight, the supplier must inform the buyer at least of the substance name. Lead metal was added to the Candidate List in 2018; therefore an Article 33 notification is mandatory for a CuZn39Pb3 part (3% Pb): "This article contains lead (CAS 7439-92-1) above 0.1%." This does not mean the part is prohibited; it is an information obligation.
- SCIP database: Notification to ECHA's SCIP database for articles containing SVHCs placed on the EU market (from 2021); the obligation lies with the manufacturer/importer in the EU, the Turkish supplier provides the necessary information.
- Annex XVII restrictions: Prohibition of certain substances in certain uses (for example lead limits in consumer products, nickel release); may be relevant depending on the part's end use.
- Annex XIV authorisation: The use of substances such as Cr(VI) compounds is subject to authorisation; the plating shop must operate within an authorised supply chain. This is the responsibility of the plater rather than the buyer of the machined part.
The Candidate List is updated twice a year; the declaration must contain the date and list version.
Status of Typical Materials
| Material | RoHS | REACH Article 33 |
|---|---|---|
| C45, 42CrMo4, S355 (structural and heat-treatable steels) | Compliant (no restricted substance) | No notification required |
| 11SMnPb30 (leaded free-cutting steel) | Compliant with exemption 6(a) | Lead notification required (0.2–0.35%) |
| 1.4301, 1.4404, 1.4305 (stainless) | Compliant | No notification required (1.4305 sulphur-bearing, no lead) |
| 6082, 6061 (aluminium) | Compliant | No notification required |
| 2011, 2007 (leaded aluminium) | Compliant with exemption 6(b) | Lead notification required |
| CuZn39Pb3, CuZn40Pb2 (leaded brass) | Compliant with exemption 6(c) | Lead notification required |
| CuZn21Si3P (lead-free brass) | Compliant | No notification required |
| POM, PA (engineering plastics) | Generally compliant; raw material declaration required | Depends on additives; raw material declaration required |
The Declaration to Request from the Supplier
A good compliance declaration contains: supplier and buyer details, part number and revision, material designation (EN number), RoHS declaration and the exemption relied on, REACH Article 33 notification (substance name, CAS number, approximate proportion) or the statement "Candidate List substances are not present above 0.1%", the reference Candidate List date, a Cr(VI)-free declaration if there is a coating with reference to the plater's declaration, signature and date. The basis of the declaration is the raw material supplier's 3.1 certificate (chemical analysis) and the plater's own declaration; the supplier keeps these on file and attaches them on request. Laboratory testing (XRF or ICP) is done only if the buyer specifically requests it and is priced separately.
Checklist for the Buyer
- State in the RFQ whether the part goes into a product within RoHS scope.
- Clarify whether you want exempted compliance with a leaded alloy or a lead-free material.
- Write "Cr(VI)-free" in the coating specification.
- Check that the declaration contains the date, Candidate List version and part revision.
- Compare exemption expiry dates with your product life cycle; a material change may be required when an exemption ends.
- Keep the declaration in the part file together with the material certificate.
Frequently Asked Questions
Is a leaded brass part in breach of RoHS?
No; with Annex III exemption 6(c), copper alloys containing up to 4% lead are compliant. However, the lead content must be notified under REACH Article 33.
Should the contract supplier carry out laboratory testing?
It is not mandatory; the declaration is based on the raw material certificate. If the buyer wants independent testing, it is carried out separately and priced.
Is RoHS required for every part?
No; only for parts used in electrical/electronic equipment. Machinery, hydraulic or structural parts are outside the scope; REACH, however, applies to every article.
Is lead-free brass more expensive?
The material is 10–25% more expensive and machining time is 15–30% longer; the part price typically rises by 15–30%. If the exemption is sufficient, the leaded alloy is the economical choice.
Conclusion
RoHS and REACH compliance can usually be achieved for machined metal parts; for leaded alloys it is enough to rely on the correct exemption and make the REACH notification completely. Writing the scope and expectation in the RFQ as a buyer ensures that the supplier gives the correct declaration the first time. For your parts requiring a RoHS/REACH declaration, send the technical drawings via our quote form; we quote with a scope that includes material certificate and compliance declaration. You can see our documentation system in our quality assurance article.
