RoHS and REACH Declarations for Machined Metal and Plastic Parts

A compliance lead asks a machine shop for its RoHS and REACH declaration for part 4471. What comes back is often a mill certificate for 6061-T6 and a one-line statement that the part is compliant. Neither answers the question — the two sides are using the same words for different things.

This article separates the regimes, explains what a valid declaration contains, and sets out where machined parts fail. It is a supplier's explanation, not legal advice; your compliance team should confirm how the obligations apply to your article.

What RoHS actually restricts

RoHS restricts ten substances in electrical and electronic equipment. The first six have applied since 2006; the four phthalates were added in 2015 and apply to EEE placed on the market from July 2019.

The limits apply at homogeneous material level, not to the finished part. A steel bracket with zinc-nickel plating and a painted face has three materials — substrate, plating, paint — and each must comply separately. Averaging across the part is not permitted, and that is where well-meaning declarations go wrong.

Lead matters most for machined parts, because it is deliberately added to some alloys for machinability. The relevant exemptions are narrow and time-limited: lead as an alloying element in steel up to 0.35%, in aluminium up to 0.4%, and in copper alloys up to 4% by weight. They have expiry dates and are periodically reviewed, so confirm current status before relying on one. A 360 brass with 2.5-3.5% lead sits inside the copper alloy exemption today — which is why a blanket claim that a part is "lead-free" is often wrong.

Why a mill certificate is not a RoHS declaration

A material certificate, or mill cert, is a statement of chemical composition for a specific heat of metal. It tells you the alloy chemistry to a specified standard. It does not cover:

• Coatings and platings applied after machining.
• Lubricants, cutting fluids and residue left on the surface.
• Adhesives, threadlockers, inserts and O-rings fitted to the part.
• Packaging, labels and inks.
• Any subcontracted finishing operation.

A mill cert can support a declaration for the substrate, not be the declaration. If that is all you receive, you have evidence for perhaps 40% of the bill of materials and none of the processes.

A usable declaration, by contrast, names the part number and revision, states the regulation and the limits, covers every homogeneous material including coatings and finishes, and is signed by someone with authority. It should also state the basis: testing, supplier declarations or engineering assessment.

See also: CBAM and Machined Metal Parts: The Supplier View and Export Control and Machined Parts: ECCN, EAR99 and Deemed Export.

REACH: the 0.1% threshold and Article 33

REACH works differently: instead of a fixed restricted list there is a Candidate List of substances of very high concern, updated twice a year and currently running to more than 240 entries.

The obligation that reaches a machine shop is Article 33. If an article contains a Candidate List substance above 0.1% by weight of that article, the supplier must give the recipient enough information to allow safe use — at minimum the name of the substance. For consumers, the same information must be provided on request.

Four practical points that decide most conversations:

1. The threshold is per article, not per part or per shipment. An article is an object that gets a shape during manufacture. A bracket is an article. A coating on a bracket is arguably a separate article or part of one, and the interpretation matters.
2. 0.1% means 0.1% w/w of the article, not of the material. A small insert with 5% of a substance inside a 200 g housing may be below the threshold at housing level.
3. There is no fixed statutory deadline for answering a request, though many customers impose 45 days contractually. Build the process so you can answer in days.
4. EU-based suppliers have SCIP obligations. If you place articles on the EU market, you may need to notify ECHA's SCIP database. A non-EU shop selling to an EU importer is not the one filing, but the importer will need your data to do it.

How to ask for the right document

The fastest way to get a usable answer is to ask a precise question with a template attached.

Ask for a full material declaration at homogeneous material level, covering substrate, coating, plating, lubricant residue and fitted components, mapped to the ten RoHS substances and the current Candidate List. Where a substance is above threshold, ask for the name and concentration band; where it is below, ask for the basis — supplier declaration, test report or engineering assessment.

Three questions weed out weak declarations quickly:

• Which revision of the Candidate List was assessed, and on what date?
• Does the declaration cover the coating and the packaging, or only the metal?
• Who signs it, and what happens when the Candidate List updates?

A shop that cannot answer the second question is providing a material statement, not a product declaration; that is acceptable if both sides know which.

Most risk sits in finishing. A chromate coating on zinc-plated steel is a genuine Cr VI question; a clear anodize on aluminium is not; a passivated 316 part is not either, because passivation does not create hexavalent chromium. Knowing which finishes are inherently low risk focuses the questions.

Our capabilities page lists the finishing processes we run and which ones carry a substance declaration, and the materials page covers the grades we stock, including leaded and unleaded brass if your drawing allows either. If a drawing permits "brass, free machining" without naming the grade, the declaration outcome changes with the grade chosen — worth fixing at the drawing stage.

Where machined parts actually fail

Failures cluster:

1. Leaded brass or steel specified generically, where the exemption is assumed rather than verified.
2. Plating and coating subcontracted without a substance declaration flowing back.
3. O-rings, seals and thread inserts bought as catalogue items and never assessed.
4. Packaging — printed labels, VCI paper and plastic bags, which are often in scope for the finished product even though nobody thinks of them as part of the part.

Each is fixable with a checklist at quoting stage; the expensive version is discovering it after your customer has declared.

Frequently asked questions

Is a machined aluminium bracket subject to RoHS on its own?

RoHS applies to electrical and electronic equipment, not to a bare bracket. As a component, however, the bracket must not prevent the finished EEE from complying, so customers flow the requirement down. Treat the request as contractual even where the regulation does not directly catch the part.

What is the difference between a RoHS declaration and a REACH declaration?

RoHS is a restricted-substance regime with ten named substances and fixed limits at homogeneous material level. REACH is a broader framework where the operative obligation for articles is the Candidate List threshold of 0.1% w/w and the duty to communicate. One document can cover both, but it must address both tests — many "RoHS/REACH compliant" statements address neither in detail.

Do we need testing, or is a supplier declaration enough?

Testing is only required where you cannot otherwise demonstrate compliance. For most machined metal parts, mill certificates, coating declarations and an engineering assessment are accepted if documented and traceable. Testing is usually reserved for suspect coatings, unknown platings or a dispute.

How often should declarations be refreshed?

At minimum when the Candidate List updates, twice a year, and whenever the part, material, finish or subcontractor changes. A declaration dated three years ago with no revision reference is hard to defend, so build the review into document control.

Related reading

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• Supplier ESG Questionnaires: How a Small Machine Shop Answers2026-11-06