RoHS and REACH for Imported Metal Parts

This guide is for procurement and quality teams sourcing machined, cast or fabricated metal parts for products sold into the EU. It explains what to ask a supplier for and how to organise the evidence. It is not a legal opinion, a CE declaration, or a promise that a part is compliant for every end use. Confirm classification, scope and product obligations with your EU compliance lead or qualified adviser.

RoHS and REACH answer different questions

RoHS and REACH are often requested together, but they have different scope and evidence paths. The European Commission explains that the RoHS Directive restricts certain hazardous substances in electrical and electronic equipment. A standalone CNC housing or bracket is not automatically EEE simply because it will be fitted into an electronic product; the product owner needs to determine whether and how RoHS applies to the finished equipment and its components.

REACH is broader. ECHA’s importer guidance distinguishes substances, mixtures and articles. A machined metal part is commonly evaluated as an article, but the correct treatment depends on the supplied item, coating, lubricant residues, packaging and intended market role. Do not copy a declaration from a different alloy or finish and assume it covers the part you are buying.

What records to request for an imported metal part

Request evidence that matches the actual build. A useful file is specific about alloy/grade, temper where relevant, coating or surface treatment, part number, revision and supplier. A generic company letter without those details is weak evidence because it cannot be reconciled to the delivered product.

• Part identity: part number, drawing revision, description, quantity and purchase order reference.
• Material identity: alloy/grade, material certificate or declaration where agreed, heat/lot reference when the programme requires traceability.
• Surface-process identity: plating, paint, anodising, conversion coating, passivation, heat treatment or adhesive/process information that can affect restricted-substance review.
• Restricted-substance declaration: a project-specific supplier declaration stating the parts, materials and processes it covers, its issue date and limitations.
• SVHC communication: available Candidate List information for the supplied article when applicable, including sufficient information for safe use.
• Change control: notification path if material, finish, source or formulation changes from the agreed build.

Sendot can review material, finish and inspection requirements as part of the RFQ. Our quality-assurance page explains the incoming, in-process and final inspection context. Availability of chemical, coating or upstream data must be confirmed for the specific material and supply chain; it should not be assumed from a website claim.

How SVHC communication works for articles

The REACH Candidate List changes over time, so use the current list and do not hard-code a stale count into a purchase specification. ECHA states that a supplier of an article containing a Candidate List substance above 0.1% weight by weight must provide sufficient information to allow safe use, including at least the substance name; consumer requests have a 45-day response requirement. Read ECHA’s current article communication guidance and confirm how it applies to your product.

For a buyer, the practical rule is to name the supplied article and ask the supplier what the declaration covers. For a coated metal part, the relevant review may include base material and surface treatment. Do not ask for “REACH compliant” in isolation; ask whether Candidate List information has been assessed for the specified part, material and finish, on what date, with which limitations and what notification will occur if those inputs change.

A supplier-document request you can put in an RFQ

1. Define the item. State whether you are buying a finished article, component, assembly, material or a part for EEE; include part number and revision.
2. Freeze material and finish. List alloy/grade, plating, paint, conversion coating, heat treatment and any approved alternates.
3. Name the programme requirement. State the customer specification, restricted-substance list, RoHS/REACH request, markets and required declaration format.
4. Ask for availability before award. Have the supplier identify which material, process and upstream records can be supplied and which cannot.
5. Set document timing. Define whether documents are needed at quotation, first article, shipment or a controlled release point.
6. Control changes. Require notice before a proposed material, finish, source or process change that could affect the declaration.
7. Keep the release file together. Store the declaration with the PO, drawing revision, inspection report and shipment/lot information.

This same evidence discipline helps with other supply-chain requests. Our UFLPA traceability guide covers origin and shipment evidence for U.S.-bound goods, while our EU CBAM guide explains why material and production data requests should be handled separately from an unsupported compliance certificate.

Responsibility boundaries: supplier, importer and product owner

There is no credible one-line guarantee for every metal part and market. A well-run supplier relationship makes the evidence trail clearer: document the requirement before production, match records to the delivered configuration, disclose limitations, and keep responsibility decisions with the party legally responsible for them.

How to avoid weak RoHS and REACH evidence

Do not use a blanket declaration for every alloy and finish. Tie the record to the part and revision. Do not confuse a material certificate with a restricted-substance declaration. Each answers a different question. Do not wait until the goods are in transit. If a coating source or SVHC record is unavailable, the sourcing or design choice may need attention before production.

For an imported metal-part RFQ, upload the drawing, material and finish requirements, intended market and document template through our request-a-quote form. Sendot can confirm what manufacturing and quality documentation is available for that specific requirement. Your EU importer, product owner and compliance adviser retain the decision on applicability and market release.

Frequently asked questions