If you sell equipment into the EU, someone in your customer's compliance team will ask for a RoHS and REACH declaration on the sheet metal enclosure. It is one of the first documents requested and one of the least understood. Buyers ask for "RoHS compliance" as though it were a single certificate; suppliers answer with a PDF that may or may not cover the actual part. This guide is written for the buyer: what RoHS, REACH and SCIP each actually require of a metal enclosure, which substances really matter in sheet metal, and how to tell a real declaration from an inherited one.
Key Takeaways: RoHS and REACH for Sheet Metal Enclosures
- RoHS, REACH and SCIP all use a 0.1% threshold, but they apply it to different things. Conflating them is the most common compliance error.
- RoHS limits are evaluated per homogeneous material, not per finished part. The coating, the plating, the base metal and the label ink are each assessed separately.
- In sheet metal, the realistic risk points are hexavalent chromium in conversion coatings, cadmium in some older plating systems, and lead in brass hardware — not the steel itself.
- Annex III exemptions for lead in metal alloys exist but carry expiry dates and the clause numbering has been revised more than once. Quote the current text, not a remembered clause number.
- Ask for the compliance file in the RFQ, not after the PO. Some documents must be requested when the material is purchased.
RoHS, REACH and SCIP: three different "0.1%" numbers
All three regimes use a 0.1% threshold, which is why they get mixed up. RoHS applies 0.1% per homogeneous material in EEE; REACH applies 0.1% w/w SVHC to the article as placed on the market; SCIP requires that information be submitted to a database. Same number, three different objects.
| Regime | What it is | Where the 0.1% applies | What you receive |
|---|---|---|---|
| RoHS (Directive 2011/65/EU, as amended) | Restriction on listed substances in electrical and electronic equipment | Per homogeneous material, by weight | Declaration of conformity and technical file; substance declarations from suppliers |
| REACH (Regulation (EC) No 1907/2006) | Registration, evaluation, authorisation and restriction of chemicals | SVHC above 0.1% w/w in the article as placed on the market | SVHC declaration; communication down the supply chain; Annex XVII restriction compliance |
| SCIP (under the Waste Framework Directive) | Database of substances of concern in products | SVHC above 0.1% w/w in the article | SCIP notification by the EU-based producer or importer |
The practical consequence: a part can be RoHS-clean on every separate material layer and still owe a REACH communication, and it can owe a SCIP notification without failing either restriction. Same number, three different obligations.
For enclosures that go into a certified assembly, these documents sit alongside the product certification file. See our enclosure certification guide (UL 508A / IEC 61439) for how the electrical-side paperwork fits together.
What RoHS 3 actually restricts in a metal enclosure
RoHS restricts the listed substance groups at 0.1% by weight in homogeneous materials, except cadmium at 0.01%. Four phthalates were added by the 2015 amendment, which is why the current list is informally called "RoHS 3."
| Substance | Limit | Where it realistically appears in sheet metal work |
|---|---|---|
| Lead (Pb) | 0.1% | Brass hardware, some free-machining alloys, older solders, some pigment systems |
| Cadmium (Cd) | 0.01% | Older cadmium plating systems; some pigments and stabilisers |
| Hexavalent chromium (Cr VI) | 0.1% | Chromate conversion coatings and passivation — the main real risk point |
| Mercury (Hg) | 0.1% | Rarely present in metal enclosures |
| Polybrominated biphenyls / diphenyl ethers (PBB / PBDE) | 0.1% | Flame retardants — relevant to plastic trims, gaskets and cable insulation |
| DEHP, BBP, DBP, DIBP | 0.1% each | Plasticised PVC: gaskets, edge trim, cable jacketing, some label stock |
Brominated flame retardants are a plastics question rather than a metal one: where brominated flame retardants actually sit in an enclosure build maps the parts that carry them.
The homogeneous material rule is the part buyers get wrong. It means one material that cannot be mechanically separated into different materials. A powder-coated galvanised steel panel is therefore assessed as several homogeneous materials: the steel, the zinc layer, the conversion coating, and the paint film. Compliance of the steel says nothing about compliance of the paint.
That is why the finish matters as much as the base metal. See surface finishing options for enclosures, and specifically corrosion resistant coatings and plating, since conversion coatings are where hexavalent chromium enters. Chromium-free and trivalent processes are the usual route to a RoHS-compliant finish. Powder coating is itself a homogeneous material and needs its own declaration — covered in our powder coating vs liquid painting comparison. For aluminium, our anodizing guide explains what goes into the oxide layer.
Do not forget the small parts. A printed nameplate, a label with adhesive, a gasket extrusion and a cable gland insert are all materials in the assessment. See nameplate and labeling requirements — the marking side and the substance side are the same conversation. Two of those small parts carry most of the plasticiser risk: the gasket and seal materials where plasticisers actually live, and the inserts in cable glands and their plastic inserts.
The metal-specific exemptions — and why you must quote the current text
RoHS Annex III contains exemptions, and several of them matter to metal parts — most notably the long-standing provisions allowing lead above the general limit in certain steel, aluminium and copper alloys. These are why brass hardware and some free-machining steels can be used in compliant equipment.
Four cautions, in order of how often they cause trouble:
- Exemptions are time-limited. They carry expiry dates and are reviewed on a cycle. An exemption that was valid when a product was designed may have lapsed by the time it is manufactured.
- Clause numbering has been revised more than once. If a supplier declaration cites only the parent clause such as "6(a)" or "6(b)" without the sub-entry — for example 6(a)-I or 6(b)-II — verify it against the current Annex III text before accepting it.
- Exemptions are substance-, material- and category-specific. An exemption for lead in copper alloys does not cover lead in a paint pigment.
- The clause structure itself has been rewritten. Three delegated directives adopted in September 2025 — (EU) 2025/1802, (EU) 2025/2363 and (EU) 2025/2364 — restructured the lead exemptions, adding sub-entries for machining steel (6(a)-I), batch hot-dip galvanised steel (6(a)-II, lead reduced to 0.2%) and certain aluminium and casting alloys. They entered into force on 11 December 2025 and have applied since 1 July 2026. The parent entries now carry hard expiry dates: 6(a) expires 11 December 2026 and will not be renewed; 6(a)-I and 6(a)-II expire 30 June 2027; 6(b) expires 11 June 2027; 6(c) expires 30 June 2027. Cite the sub-entry and check the date for your product category. In practice the lead exposure reaches your bill of materials through the brass and plated fasteners that carry most of the lead risk in an assembly, which is why hardware is worth specifying separately from the sheet.
Because the expiry dates now differ by sub-entry, treat any exemption quoted without a sub-entry and a date as unverified. Confirm the current text against official EU sources before you rely on it — this area has changed more than once and a remembered clause number is the fastest route to a non-compliant part.
The practical instruction for buyers: do not write clause numbers into your specification. Write the requirement — "materials shall comply with the restriction list as currently in force, with any reliance on Annex III exemptions documented, identified by clause and expiry date, and supported by supplier declarations." That is enforceable and it does not go stale.
Choice of base metal interacts with this: see stainless steel vs carbon steel enclosures for where each sits. For the wider view, how the base metal choice interacts with the substance declaration covers the grades beyond those two.
REACH SVHC and why the candidate list matters to metal parts
REACH works differently from RoHS. Its candidate list of substances of very high concern is updated periodically, and the obligation attaches to the article: if an SVHC is present above 0.1% w/w in the article, information must be communicated down the supply chain, and in some cases notified to ECHA.
For metal enclosures the relevant point is that SVHC listing is not only about substances you deliberately add. Metals and alloys appear on the candidate list in their own right, and substances can enter through coatings, sealants and treatments. Treatments you did not specify count too: conductive coatings and shielding treatments applied for EMI reasons are coatings like any other. A declaration that says "no SVHC intentionally added" is not the same as a declaration that says "no SVHC above 0.1% in this article."
Ask for the second sentence. Elastomers and sealants are the usual gap, which is why elastomer and sealant choices in a washdown enclosure deserves its own line in the declaration request.
Because the list is updated regularly, also ask for the reference date of the declaration — which version of the candidate list the supplier assessed against. A declaration that is two years old assessed a shorter list.
The compliance file package a sheet metal shop can actually issue
This is what a competent fabricator should be able to put together. Ask for it in the RFQ, because items 1 and 2 must be secured when the material is bought.
Documents that must be ordered with the material
| Document | Why it cannot wait |
|---|---|
| Material declaration with mill certificate and heat number | Traceability to the coil or sheet lot only exists at purchase |
| Coating and plating supplier declarations | This is where Cr(VI) and cadmium are addressed |
| RoHS declaration with exemptions named | Must cite the sub-entry, the clause and the expiry date |
Documents that can be issued at inspection
| Document | What it must state |
|---|---|
| REACH declaration | SVHC status, the candidate list version referenced, whether any SVHC exceeds 0.1% in the article |
| Third-party test report | The test method named, not just a pass |
| Inspection and traceability records | The declaration batch linked to the delivered lot |
| Change notification commitment | A change of material, plating supplier or paint supplier triggers a new declaration |
The full list, in order:
- Material declaration with mill certificate and heat number, traceable to the coil or sheet lot.
- Coating and plating supplier declarations for every applied finish — this is where Cr(VI) and cadmium are addressed.
- RoHS declaration stating the basis: substance list, threshold, homogeneous-material approach, and any exemptions relied on with clause and expiry date.
- REACH declaration stating SVHC status, the candidate list version referenced, and whether any SVHC exceeds 0.1% in the article.
- Third-party test report where required, with the test method named.
- Inspection and traceability records linking the declaration batch to the delivered lot — see our quality control and inspection records.
- Change notification commitment — the promise that a change of material, plating supplier or paint supplier triggers a new declaration.
Item 7 is the one buyers forget and the one that matters most over a three-year programme. Without it, compliance silently drifts.
If you are assembling the enquiry yourself, our sheet metal RFQ checklist shows where these documents belong in the request.
XRF screening vs IEC 62321 testing — and how declarations go wrong
Two tools, different jobs.
What XRF screening can and cannot tell you
XRF screening (the relevant part of the IEC 62321 series covers screening by X-ray fluorescence) is fast, non-destructive and good at catching heavy elements in metal and coatings. It is weak on light elements and cannot determine oxidation state — so it will flag total chromium but cannot tell you whether it is hexavalent. For a Cr(VI) question you need a wet chemical method.
When full laboratory testing is required
Full IEC 62321 testing is slower and costs more, but it is what you need when a declaration has to be defensible or when the substance is an organic compound such as a phthalate or a brominated flame retardant.
Four ways declarations turn out to be wrong
- Inherited declaration. The supplier passes on a document from their material supplier without confirming it covers your part, your finish, or the current substance list.
- Expired test report. A report from years ago, still circulating, assessed against an older substance list and an older Annex III.
- Phthalate gap. Metals tested, plastics and gaskets ignored. Phthalates live in the soft parts, not the steel.
- Process residue. The base metal is clean, but a treatment bath, a marking ink or an assembly aid introduces the substance.
Ask which of these the declaration rules out. If a supplier cannot say, treat the declaration as untested.
PFAS, conflict minerals and other watch items
Two areas to keep on the radar without over-engineering today:
- PFAS. Restrictions on per- and polyfluoroalkyl substances are under active development in the EU, with implications for certain coatings and treatments. If your enclosure spec relies on a fluorinated coating, ask the supplier to confirm its PFAS status now, so a future restriction does not arrive as a surprise in the middle of a programme.
- Conflict minerals. Tin, tantalum, tungsten and gold are covered by EU rules for importers. Sheet metal is rarely the risk point, but if your enclosure programme includes electronics assembly or plated finishes, expect the question. Confirm the current requirement against official EU sources rather than a summary article.
Both are moving targets. Treat them as questions to ask at design time, not as certificates to chase at delivery.
Frequently Asked Questions
Is RoHS compliance the same as REACH compliance?
No. RoHS restricts a defined list of substances per homogeneous material in electrical and electronic equipment. REACH covers a much wider chemical universe, with obligations triggered by SVHC content in the article. A part can satisfy one and still generate obligations under the other.
Does RoHS apply to a bare metal enclosure?
It applies to electrical and electronic equipment placed on the EU market. Whether a specific enclosure is in scope depends on the equipment it goes into and how the finished product is classified under the EEE categories — confirm against the current scope guidance rather than assuming. On its own, the enclosure is only RoHS-compliant as part of the assessed equipment.
What is a homogeneous material?
One material that cannot be mechanically separated into different materials. On a powder-coated galvanised panel, the steel, zinc layer, conversion coating and paint film are each assessed separately.
Why does hexavalent chromium matter for sheet metal?
Because chromate conversion coatings and some passivation treatments are the realistic route by which Cr(VI) enters a metal part. Chromium-free or trivalent alternatives exist and are the usual answer.
Is XRF screening enough?
No — not on its own. XRF cannot determine oxidation state, so it cannot tell you whether chromium is hexavalent. It is a good screening tool for heavy elements in metal and coatings. For Cr(VI), or for organic substances such as phthalates, you need laboratory analysis against the relevant test method.
How often should declarations be refreshed?
At minimum whenever the material, plating supplier or paint supplier changes, and periodically against the current substance lists. Ask for a change-notification commitment in the contract.
Should I ask for these documents before or after the order?
Before. Material certificates and coating declarations have to be requested when the material is purchased. Asking at delivery means reconstructing traceability from records, which takes time and sometimes is not possible.
Ask for the file before you ask for the part
Compliance is not a certificate you collect at the end. It is a set of documents generated at material purchase, coating and inspection — and if you do not ask for them in the enquiry, you will be asking for them during a shipment delay. That is the difference between an enclosure that is RoHS-compliant on paper and a RoHS compliant sheet metal enclosure you can defend in an audit.
Send us your enclosure drawing and target market, and we will tell you which declarations we can issue with the part, which need a third-party report, and which need to be ordered at material-purchase time.
Selling into the EU? Send your drawing and we will map the compliance file you need — before your customer's compliance team asks for it.