Guide
What does a RoHS certificate cover for machined, plated and cast metal parts, and what should you request?
A RoHS certificate is a supplier’s signed declaration that each homogeneous material in a part (the base alloy, the plating, the conversion coat, the paint) stays under the EU restricted-substance limits, or uses a named exemption. EU law does not issue or require a third-party certificate for RoHS: the maker of the finished electrical product declares conformity itself and keeps the technical file, and component suppliers feed that file with declarations and evidence.
By Saola Manufacturing engineering team · Published · Updated
For metal parts the restricted substances that actually matter are few: lead in free-machining steel, aluminum and brass, hexavalent chromium in older chromate finishes, and occasionally cadmium. This guide covers how RoHS and REACH treat each one, which exemptions a machined part relies on, how to write the drawing note, and what a declaration worth filing has to contain. It summarizes the public legal texts on EUR-Lex and ECHA; it is engineering guidance, not legal advice.
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Does RoHS even apply to a bracket, bushing or housing?
RoHS applies to electrical and electronic equipment and to the parts inside it, so a machined bracket is in scope when it ends up in a product that needs a plug, a battery or a current to work. A valve body for a water main or a purely mechanical assembly is usually outside RoHS, although REACH still applies to it.
The scope sits in Article 2 of Directive 2011/65/EU, the recast often called RoHS 2. Since the open-scope change in 2019, almost every category of equipment is covered unless specifically excluded, which is why many OEMs now ask every metal-part supplier for a declaration rather than sorting parts by end use. That is a reasonable policy: the supplier often does not know where a part will end up, and the cost of declaring a compliant part is small.
Great Britain has its own copy of the rules in the RoHS Regulations 2012, which track the EU substance list closely; Northern Ireland follows the EU directive. Vehicles are handled separately under the End-of-Life Vehicles Directive, which has its own heavy-metal limits and its own exemption annex. The US has no federal RoHS law, but parts that ship to an EU or UK assembler, or into a product a US customer exports, inherit the requirement anyway.
The point engineers most often miss is the phrase “homogeneous material.” The limits are not measured on the whole part. They apply to each material that cannot be mechanically separated: the steel body, the zinc layer and the chromate film on top are three materials, judged one by one. A thin conversion coat can fail on its own even though it is a tiny fraction of the part’s weight.
| Substance or exemption | Limit (% by weight) | Where it shows up on metal parts |
|---|---|---|
| Lead (Pb) | 0.1 | Free-machining steel, aluminum and brass; solder; some old paints |
| Mercury (Hg) | 0.1 | Rare in machined or cast parts |
| Cadmium (Cd) | 0.01 | Cadmium plating; impurity in some zinc and recycled alloys |
| Hexavalent chromium (Cr VI) | 0.1 | Yellow, olive and black chromate on zinc; Type I chem film; dichromate anodize seal |
| PBB and PBDE flame retardants | 0.1 | Plastics only; not in bare metal |
| DEHP, BBP, DBP, DIBP phthalates | 0.1 each | PVC protective caps, masking plugs, sleeves left on as shipped |
| Exemption 6(a)-I: lead in steel for machining (expires 30 June 2027) | up to 0.35 | Leaded free-machining steel such as 12L14 |
| Exemption 6(b)-II: lead in aluminum for machining (expires 11 June 2027 for most categories; not renewed) | up to 0.4 | Leaded free-machining wrought alloys such as 2011 |
| Exemption 6(b)-III: lead in aluminum casting alloys from recycled scrap (expires 30 June 2027) | up to 0.3 | Secondary die-casting alloys such as ADC12 |
| Exemption 6(c): lead in copper alloy (expires 30 June 2027) | up to 4 | Free-cutting brass such as C36000 |
Is leaded brass, 12L14 or 2011 aluminum allowed under RoHS?
Leaded brass and 12L14 are allowed for now, through Annex III exemptions that carry a lead cap and an expiry date, and a declaration that relies on one should name it. Leaded machining aluminum such as 2011 is being phased out: its exemption was not renewed and ends in June 2027.
The lead entries were rewritten by Delegated Directive (EU) 2025/2364, adopted in September 2025 and applied by EU member states from 1 July 2026. Free-cutting brass is the comfortable case. C36000 carries roughly three percent lead per ASTM B16, under the copper-alloy cap in exemption 6(c) of the amended Annex III, which allows up to 4% lead by weight until 30 June 2027. Leaded steel is tighter: 12L14 is specified with lead up to 0.35% per SAE J403, and exemption 6(a)-I caps lead in steel for machining at the same 0.35%, also until 30 June 2027, so a heat at the top of the range has no margin at all. The older catch-all entry 6(a) expires on 11 December 2026.
Aluminum 2011 is the trap, twice over. Its registered chemistry allows 0.20 to 0.6% lead (and the same range of bismuth) in the Aluminum Association Teal Sheets, while exemption 6(b)-II allows lead in aluminum for machining only up to 0.4%, so a 2011 bar can be fully in specification as an alloy and still fail RoHS. And the 2025 delegated directive did not renew 6(b)-II: the Commission found reliable lead-free substitutes on the market, and the entry expires on 11 June 2027 for categories 1 to 7 and 10, and on 30 June 2027 for industrial monitoring and control instruments and the open-scope category 11. For a part going into electrical equipment, move to a lead-free grade now rather than at the deadline, and confirm it machines acceptably.
Two more conditions apply to every one of these entries. First, they exclude equipment sold to the general public where a part smaller than 5 cm could be put in a child’s mouth, unless a very low lead-release rate is demonstrated. Second, the expiry dates are not the end of the story: under Article 5 of the directive, a renewal application filed at least 18 months before expiry keeps an exemption valid until the Commission decides. Before you sign off a design that depends on 6(a)-I or 6(c), read the current consolidated Annex III and the Commission’s exemption pages rather than a supplier’s summary, and ask the supplier to quote the exemption number exactly as it appears there.
Die-cast alloys need a chemistry check rather than a redesign. Zamak 3 is a high-purity zinc alloy whose specification holds lead and cadmium to trace levels. Aluminum die-casting alloys are made largely from recycled metal, and ADC12 allows up to 0.2% lead per JIS H 5302, which is above the 0.1% base limit. A heat below 0.1% needs no exemption; above it, the part relies on exemption 6(b)-III (casting alloys from recycled scrap, capped at 0.3%), or on 6(b)-I for industrial monitoring and control instruments and category 11 equipment. Recycled-content ingot is where cadmium and lead creep in, so the ingot certificate with actual chemistry is the document to ask for.
Which finishes contain hexavalent chromium, and what replaces them?
The usual offenders are yellow, olive-drab and black chromate over zinc plating, Type I chromate conversion coating on aluminum, and dichromate seals on anodize. Each has a trivalent or chromium-free replacement, and the drawing note is where the switch has to happen.
On zinc plating, the conversion film is the homogeneous material, and a hexavalent chromate film typically holds far more Cr(VI) than the RoHS limit allows. Current editions of ASTM B633 list Type V (colorless passivate) and Type VI (colored passivate) for non-hexavalent finishes alongside the older chromate Types II and III, so a legacy callout such as “zinc plate, yellow chromate” or a bare ASTM B633 Type II should be read as hexavalent until proven otherwise. A blue or clear trivalent passivate is the routine replacement; trivalent yellow and black exist, usually with a sealer.
On aluminum, MIL-DTL-5541 separates the two cleanly: Type I is the hexavalent chem film and Type II is the non-hexavalent version. Anodize itself contains no chromium unless it is sealed in dichromate or run as chromic-acid anodize, so state a non-chromate seal on any anodized part that goes into electrical equipment.
REACH reaches the same chemistry from a different side. Chromium trioxide and the dichromates are on the ECHA authorization list, so EU platers need an authorization to use them, and ECHA has been working on a broader restriction of Cr(VI) substances. That pressure is a large part of why trivalent passivates have become the default on many plating lines, including outside the EU.
One testing caveat matters here. Handheld XRF reads total chromium and cannot tell trivalent from hexavalent, so an XRF screen of a passivated part proves nothing about Cr(VI). The test for Cr(VI) in coatings on metal is the boiling-water extraction method of IEC 62321-7-1, done by a lab on sample parts.
How is REACH different from RoHS for a metal part?
RoHS is a fixed list of restricted substances with limits per homogeneous material, but only for electrical equipment. REACH applies to every article placed on the EU market and adds a duty to communicate whenever a Candidate List substance exceeds 0.1% by weight of the article, per Article 33 of Regulation (EC) No 1907/2006.
The consequence surprises buyers: lead metal has been on the ECHA Candidate List since 2018, so a leaded brass fitting that is perfectly legal under RoHS exemption 6(c) still contains a substance of very high concern above the 0.1% threshold, per the REACH Article 33 rule. The supplier must give you the substance name and enough information for safe use, and you must pass it down your chain. Since 5 January 2021, under the EU Waste Framework Directive, companies supplying such articles on the EU market also have to notify ECHA’s SCIP database.
Three details decide how a REACH declaration should read. First, the threshold is measured per article, and the EU Court of Justice ruled in 2015 that each component article in an assembly is judged on its own, so a brass insert is not diluted by the plastic housing around it. Second, the Candidate List grows over time (ECHA’s table states the date of the last update and when the next is expected), so a declaration is only meaningful against a named version of the list. Third, REACH Annex XVII carries separate restrictions that can bite metal parts directly, such as the cadmium entry, which bans cadmium plating in many applications, and the nickel entry, which limits nickel release from parts in prolonged contact with skin.
The UK runs its own REACH with a separate candidate list. For most metal parts the substances are the same, but a declaration for a UK customer should say which list it was checked against.
What should a RoHS certificate or declaration actually contain?
A useful declaration is tied to your part number and revision, names the legal texts and versions it was checked against, lists every exemption used, and is signed and dated by the legal entity that made the part. A generic company letter saying “all our products are RoHS compliant” does not belong in a technical file.
Ask for the following on every RoHS and REACH declaration for a metal part:
- Part number, drawing revision and the material and finish exactly as built.
- Directive 2011/65/EU as amended by Delegated Directive (EU) 2015/863, so the four phthalates are covered, and the UK regulations if you sell there.
- Each Annex III exemption relied on, by number, against the homogeneous material that uses it (for example, 6(c) for the brass body).
- A REACH statement naming the Candidate List version or date checked, and for any substance above threshold its name, CAS number and where it sits in the part.
- The supplier’s legal name, a signatory with a title, and a date.
- The evidence behind it, available on request: material certificates showing chemistry, the plating or coating supplier’s own declaration, and lab reports where risk justifies them.
Evidence should match risk, which is the approach of EN IEC 63000, the standard for RoHS technical documentation. A brass part relying on 6(c) needs chemistry from the bar certificate; a zinc-plated steel part needs the passivate chemistry confirmed; a bare 6061 part needs little more than its mill certificate. Commissioning a full lab panel on every part number wastes money and rarely finds anything the documents did not already show.
If you collect declarations in bulk, the IPC-1752B material declaration format lets a supplier send the same data in a structured file instead of a PDF letter. Many compliance tools import it directly.
How should RoHS and REACH be called out on the drawing and the RFQ?
Put a short compliance note in the drawing notes and name a RoHS-compatible finish explicitly, so the requirement travels with the drawing to every supplier and sub-tier plater. The RFQ then asks for the declaration as a deliverable, not as an afterthought at shipment.
A drawing note that works in practice reads: “All materials and finishes to comply with EU Directive 2011/65/EU as amended by (EU) 2015/863. Exemptions permitted: 6(c) only. Supplier to declare REACH Candidate List substances above the Article 33 threshold.” Pair it with a finish callout that cannot be read as hexavalent, for example “zinc plate per ASTM B633 Type V (trivalent clear or blue passivate), no hexavalent chromium.” On aluminum, write MIL-DTL-5541 Type II, never just “chem film.”
The common mistakes on RFQ drawings are a legacy yellow-chromate note that nobody updated, a RoHS note with no finish named so the plater picks one, leaded aluminum on a part for electrical equipment with no lead figure requested from the mill, and red or yellow PVC caps fitted over threads for shipping that end up inside the customer’s product. Each one is cheap to fix on paper and expensive to fix after the parts land.
On the finishing side, the partner plants on our surface finishing menu apply RoHS-compliant blue trivalent chromate as the standard chromate over zinc plating, and that is what we quote unless your drawing calls out something else. Chromate conversion coatings on aluminum (chem film) and decorative chrome-look plating are not on that menu, so a drawing that calls for either needs to say so before we quote. A RoHS declaration covering materials and finishes, and material certification tracing the alloy or steel grade, are available on request, as listed on our quality page. Our CNC turning line runs bar stock that includes 12L14 and 2011-T3, and also C1117 steel and 6061-T6 aluminum, which carry no added lead. If a turned part is headed for electrical equipment, tell us on the RFQ so the lead question above is settled before the grade is locked in.
Frequently asked
Is a third-party RoHS test report the same as a RoHS certificate?
No. A lab report shows that the samples tested met the limits on the day they were tested. It is useful evidence, but the legal obligation is the manufacturer’s declaration of conformity backed by a technical file, and a test report on one lot does not cover later lots made from a different heat or plating bath.
Can XRF screening prove a part is RoHS compliant?
XRF is a good screen for lead and cadmium in metals and is fast and non-destructive. It reads total chromium, though, so it cannot confirm the absence of hexavalent chromium in a passivate; that needs the Cr(VI) test in IEC 62321-7-1.
Does a stainless steel or plain aluminum part need a declaration?
If it goes into electrical equipment, yes, but the evidence is light: the mill certificate showing chemistry is usually enough, since common grades such as 304, 316, 6061 and 7075 do not add lead (free-machining aluminum such as 2011 is the exception). The risk on those parts is in the finish and in anything attached for shipping, not in the base metal.
How often should a declaration be refreshed?
Ask for a new REACH statement whenever ECHA updates the Candidate List that matters to your parts, and a new RoHS declaration whenever the material, finish, plater or an exemption relied on changes. Many buyers simply request an annual reconfirmation per part number.
Is lead-free brass required for RoHS?
Not while exemption 6(c) is in force; it currently runs to 30 June 2027, and a timely renewal application would keep it valid until decided. Lead-free brass is driven mainly by drinking-water rules, which are stricter than RoHS; see the related guide on NSF 61 and NSF 372 for those parts.
Sources
- Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), with Annexes II and III, EUR-Lex, 2011 (read as consolidated 2026)
- Commission Delegated Directive (EU) 2025/2364 replacing RoHS Annex III entries 6(a) to 6(c) on lead as an alloying element in steel, aluminum and copper alloys, EUR-Lex, 2025
- Commission Delegated Directive (EU) 2015/863 amending Annex II (four phthalates), EUR-Lex, 2015
- Regulation (EC) No 1907/2006 (REACH), including Article 33 and Annex XVII, EUR-Lex, 2006
- Candidate List of substances of very high concern for authorization, European Chemicals Agency, accessed 2026
- Authorization List (REACH Annex XIV), European Chemicals Agency, accessed 2026
- SCIP database (Waste Framework Directive), European Chemicals Agency, notifications required since 5 January 2021
- RoHS Directive overview, European Commission, accessed 2026
- The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012, legislation.gov.uk, 2012
- International Alloy Designations and Chemical Composition Limits for Wrought Aluminum and Wrought Aluminum Alloys (Teal Sheets), The Aluminum Association, 2025