RoHS, REACH, SCIP and Proposition 65 — substance compliance
Substance rules rarely stop a bolt, but they stop consignments — usually because a declaration was missing rather than because a substance was present. Here is what applies, and what we can hand to your compliance team.
What applies to fasteners and hardware
| Regulation | Applies when | Practical concern for fasteners and hardware |
|---|---|---|
| RoHS 2011/65/EU (and delegated amendments) | Electrical and electronic equipment — fasteners as components are supplied into scope through the finished product | Cadmium and hexavalent chromium in coatings; lead in machining steels; phthalates in plastic parts (solar clips, handles, wing grips) |
| REACH SVHC — candidate list, Article 33 | Any article placed on the EU market containing a candidate-list substance above 0.1 % w/w | Duty to communicate along the supply chain. The candidate list is updated roughly twice a year — declarations should reference a date, not "REACH compliant" |
| REACH Annex XVII, entry 27 — nickel release | Articles in prolonged skin contact | Handles, hinges, hasps, castors, padlocks and decorative hardware — relevant for consumer hardware, not for structural bolts |
| SCIP database | Articles containing SVHC above 0.1 % w/w placed on the EU market | Notification is made by the EU supplier/importer; we provide the component composition data needed to file it |
| ELV 2000/53/EC | Automotive applications | Lead, cadmium, mercury, hexavalent chromium limits for vehicle components |
| California Proposition 65 | Consumer products sold in California | Warning obligations where listed substances exceed safe-harbour levels — relevant to hardware sold through retail |
What we provide
- Material and coating declaration per product family, listing alloying elements, coating chemistry and any intentional additives.
- SVHC screening against the candidate list revision you specify (we ask for the date, because the list moves).
- RoHS substance data for coatings and plated finishes — including confirmation that trivalent (Cr3) passivation is used rather than hexavalent chromium.
- Third-party testing on request: XRF screening, wet chemistry, phthalate and PAH testing through SGS, BV, TÜV or Intertek at your cost, with the report issued to your name.
- Support for SCIP filing: component-level composition and article identification for the EU supplier who files.
A note on "RoHS compliant" certificates
RoHS is a restriction on electrical and electronic equipment, not a general product certification. Statements like "RoHS certified" for a loose bolt are usually meaningless. What is useful is a dated substance declaration against a named test method, plus test reports where the end product is genuinely in scope.
Frequently asked questions
Do you use hexavalent chromium passivation?
No. Our zinc plating uses trivalent (Cr3) passivation as standard. Trivalent processes give lower corrosion performance in very aggressive environments, so where that matters we recommend hot-dip galvanizing or a zinc-flake system instead.
Which SVHC list revision do your declarations reference?
We test against the revision you specify. Tell us the date or the entry count your compliance team is working to, and the declaration will state it explicitly rather than claiming generic REACH compliance.
Can fasteners require a Proposition 65 warning?
For consumer-facing hardware in California, yes — typically where nickel, lead or phthalates exceed safe-harbour levels. Industrial fasteners sold business-to-business fall outside the consumer context.
Need a compliance statement or document pack for your market?
Tell us the destination country and product family — we return the applicable route, required documents and lead time within 48 hours.