REACH and RoHS Compliance for Machined Parts

REACH and RoHS are two separate EU rules that appear on the same quote checklist, and they ask different questions. RoHS, Directive 2011/65/EU as amended, restricts ten substances in electrical and electronic equipment to 0.1 percent by weight in each homogeneous material, with a tighter 0.01 percent limit for cadmium. REACH, Regulation (EC) No 1907/2006, governs chemicals across every industry and requires a supplier to pass on information when an article contains more than 0.1 percent by weight of a substance on the Candidate List of substances of very high concern. For a parts buyer the practical answer is short: a machined part is not compliant or non-compliant by default. It is declared against the current state of each list, per part, by whoever places the article or the finished product on the EU market. This page explains both rules, the machining traps, and what to ask a supplier. It is engineering orientation, not legal counsel, so confirm binding decisions against the official texts or a compliance specialist.

This page is the deep REACH and RoHS treatment in the materials cluster. The wider set of material and quality-system documents, mill test reports, EN 10204 types, ISO 9001, and special-process accreditation, lives on the material certifications and standards page. Alloy chemistry notes here lean on brass and copper and engineering plastics, and terms are defined in the manufacturing glossary.

What REACH is and what it asks of you

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is an EU regulation, so it applies directly in every member state without national implementing law, and it covers chemical substances on their own, in mixtures, and in articles. An article, in REACH terms, is an object whose special shape, surface, or design determines its function to a greater degree than its chemical composition. A machined fitting is an article, and the cutting oil used to make it is a mixture. The duty that reaches a machine shop or parts supplier is the one that attaches to articles.

Registration, evaluation, authorisation, restriction

The regulation works in four stages. Manufacturers and importers of chemicals in volume must register them with the European Chemicals Agency (ECHA) and submit hazard data, and the agency then evaluates submissions and substances of concern. Substances of very high concern can move onto the authorisation list, Annex XIV, after which companies need authorisation to keep using them. Separately, Annex XVII sets conditions or bans on specific uses outright. Most of that machinery sits with chemical producers rather than machine shops. What reaches a shop is the downstream edge: the obligation to know and to communicate what is in the articles it supplies.

The Candidate List and the 0.1 percent threshold

Substances of very high concern (SVHCs) are identified on a Candidate List maintained by ECHA, covering hazards such as carcinogenicity, reproductive toxicity, or persistence and bioaccumulation in the environment. When an article contains a listed substance above 0.1 percent weight by weight, REACH Article 33 requires the supplier to give the recipient enough information to use the article safely, and at minimum the substance name. A notification duty to the agency also applies where the total quantity of that substance in the articles a producer or importer places on the market exceeds 1 tonne per year.

The list is a moving target. It is updated roughly twice a year, so a part declared clean at design time can pick up a communication duty later when a new substance is added. Do not rely on a count from a web page, including this one. Check the current list on the ECHA site before making or accepting a declaration.

Authorisation and restriction in practice

Annex XIV and Annex XVII do different jobs. A substance on Annex XIV cannot be used without an authorisation, granted for specific uses and periods, so its supply eventually dries up. A restriction under Annex XVII sets conditions on a use regardless of who uses it, for example a concentration cap in a consumer article. For a parts buyer the effect is the same: a substance moving onto either annex tends to end with a substitution programme, so alloy and finish choices made today should be checked against what is coming, not only what is listed now.

What RoHS is and where it applies

RoHS is the restriction of hazardous substances directive, 2011/65/EU, amended in relevant part by Directive (EU) 2015/863. Where REACH looks at chemicals everywhere, RoHS looks at one product family: electrical and electronic equipment. It restricts ten substances by capping their concentration in each homogeneous material used to build the product.

The ten restricted substances

A homogeneous material is one uniform substance or mixture, such as the brass of a terminal, the plastic of a connector body, or the coating on a screw, and the limit applies to each one separately rather than to the whole part. That is stricter than it sounds. Lead spread evenly across a whole assembly can still be far over the limit inside the brass alone.

The first six substances were carried over from the original directive. The four phthalates were added by Directive (EU) 2015/863, which member states had to apply from 22 July 2019, with the later date of 22 July 2021 for medical devices and for monitoring and control instruments.

Scope: what counts as electrical and electronic equipment

The directive applies across eleven equipment categories: large and small household appliances, IT and telecom equipment, consumer equipment, lighting, electrical and electronic tools, toys and leisure equipment, medical devices, monitoring and control instruments, automatic dispensers, and a catch-all for other EEE. A machined part is rarely in scope on its own. It enters the picture as a component of a product that is, and the product maker needs declarations from every supplier to declare the whole.

Exemptions and why they expire

Annex III lists applications exempt from a restriction, typically where a reliable substitute is not yet available, and Annex IV does the same for medical devices and monitoring instruments. Exemptions are not permanent. Each carries a review schedule and an expiry date, and when one lapses or is narrowed, parts that relied on it fall out of compliance on a fixed calendar. The best known set for machining covers lead as an alloying element: up to 0.35 percent in steel, up to 0.4 percent in aluminium, and up to 4 percent in copper alloy. That series lapsed on a staged schedule, July 2021 to July 2024 by category, and was then renewed: Delegated Directive (EU) 2025/2364, applying from 1 July 2026, replaced points 6(a) through 6(c) with new expiry dates running from 11 December 2026 to 30 June 2027. Treat any printed expiry as schedule, not permission, and check the current annex rather than a figure quoted in a datasheet.

REACH and RoHS side by side

The table below contrasts the two rules on the axes a buyer actually uses: what is regulated, by what mechanism, at what threshold, on whom the duty falls, and how often the rules move.

Which rule your part falls under

Ask two questions in order. Is the part going into electrical or electronic equipment placed on the EU market? If yes, RoHS applies to the finished product and the buyer will ask for substance data. Does the part, or anything on it, contain a Candidate List substance above 0.1 percent weight by weight? If yes, REACH Article 33 communication applies whether or not the part is electrical. A plastic knob on a hand tool can carry a REACH duty with no RoHS question at all, and an aluminium heatsink can be RoHS relevant with no SVHC in it.

The machining traps

Most REACH and RoHS problems in machined parts are not exotic. They come from a small set of materials and finishes chosen for performance or cost, not for chemistry.

Lead in free-machining brass and leaded steel

Free-machining brass C360 carries around three percent lead, which is what makes it the machinability benchmark, and that is about thirty times the 0.1 percent RoHS limit. The same logic applies to leaded steels such as 12L14, where lead is added so chips break instead of stringing. These materials stay usable in electrical products through the copper-alloy and steel exemptions described above, which were renewed in September 2025 and now expire between December 2026 and June 2027, so current validity is a lookup against Annex III, not an assumption. Two habits prevent surprises. One, when a customer asks for RoHS compliant brass, confirm which exemption the declaration relies on and that it is still current. Two, offer the lead-free alternative on the drawing, since many buyers now specify low-lead brass for drinking water or consumer products.

Cadmium plating

Cadmium plating gives excellent corrosion protection and lubricity, which is why it persists in aerospace and defence hardware. It is also the most tightly limited substance on the RoHS list at 0.01 percent in homogeneous material. Exemptions exist for narrow, application-specific uses and are reviewed on their own schedules, so the honest position is that cadmium plate on a general industrial or consumer part is a problem, while cadmium plate on a qualified aerospace part may sit inside an exemption, or outside the directive’s scope entirely, and the customer manages that determination. Ask rather than assume, and expect the common answer to be zinc or zinc-nickel plate instead.

Hexavalent chromium and chromate passivation

Hexavalent chromium is restricted at 0.1 percent, and its main route into a machined part is not the alloy but the finish. Chromate conversion coating, used to passivate zinc and cadmium plated parts and to treat aluminium before paint, historically used hexavalent chemistry. The industry has moved toward trivalent passivates and hex-free chemistries, but that transition is exactly the detail a generic “plated per spec” note hides. If a part carries a conversion coating for corrosion resistance or paint adhesion, ask for the coating chemistry by name, because a hexavalent process can put the whole assembly over the limit in a layer only fractions of a micron thick.

Plastics, plasticizers, and brass inserts

Two traps hide in plastic and hybrid parts. First, PVC and flexible vinyl compounds are where the four restricted phthalates live, and flexible cable jackets, grommets, strain reliefs, and overmoulded grips are the usual carriers. A metal parts supplier who also sources plastic hardware inherits the question. Second, threaded brass inserts moulded into plastic parts are a homogeneous material all of their own, and free-machining brass is the common insert stock, so the brass lead question rides into a nominally plastic component. The fix is the same either way: get the compound data sheet for the resin and the alloy declaration for the insert, and check both against the current lists. The engineering plastics page carries the resin side of that conversation.

What compliance looks like in practice

Compliance work is mostly record keeping that answers one question per part: what is in it, proven to what level, as of when.

The homogeneous material question

RoHS reasoning happens at the homogeneous material level, so the honest unit of analysis is the coating, the alloy, the plastic, and the adhesive, not the assembly. A stainless screw with a chromate passivate has at least two homogeneous materials and both must be under the limits. That is why a declaration built only from metal alloy datasheets fails review, and why finishes, coatings, labels, and solder all belong in the data set. When a supplier answers a RoHS question with a single line, ask which materials it covers.

What to ask your supplier

Ask for three things in writing. A material declaration that lists the relevant substances per homogeneous material, in a recognised reporting format, so the data is comparable across suppliers. A declaration of conformity for the specific article, naming the rules and any exemption numbers it relies on, signed and dated. And the basis for the claim, whether that is supplier test data, upstream certifications, or a materials database, so you can tell a tested claim from a forwarded claim. The material certifications page covers the mill test report side of that same evidence chain, and the same discipline applies here: a logo on a website is not proof.

Traceability and the declaration trail

Because both rules are declared against moving lists, the trail needs dates on it. Keep the declaration, the material data behind it, the coating and plating specifications, and the date each was checked against the then-current lists. Tie them to the part number and, where the work is traceable, to the material lot, the same thread the certifications page describes for mill test reports and heat numbers. When a new substance is listed or an exemption expires, that trail tells you which parts are affected instead of forcing a requalification of everything.

REACH and RoHS checklist

Run this list before quoting or releasing a part that will enter the EU market. Identify whether the finished product is electrical or electronic equipment in one of the eleven RoHS categories, and if it is, treat every homogeneous material in the part as in scope. Flag the finishes and materials that carry risk: leaded brass and steel, cadmium plate, chromate conversion coatings, PVC and vinyl, and moulded-in brass inserts. Get a written material declaration per homogeneous material, not a blanket statement. Get a signed, dated declaration of conformity naming any exemptions relied on, and check those exemptions are still current. Check the REACH Candidate List as of this writing, not as of the design date, and record the date of the check. Confirm coatings by chemistry, not by trade name. Keep the trail, part number, lot, declaration, data, and dates, so a later list update can be answered from the record. Where a decision carries legal weight, take it to a compliance specialist, because this page orients engineers and buyers, it does not give legal advice.