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What do RoHS and REACH mean for a moulded plastic part?

RoHS limits ten hazardous substances in electrical and electronic equipment. UK government guidance lists the maximum levels as 0.01 percent for cadmium and 0.1 percent for each of the other nine. These limits apply to each homogeneous material, so a plastic housing is judged on its own. REACH is broader: it covers chemicals in all products. For a moulded part, the main article duty is to pass on information when a substance on the candidate list of substances of very high concern is present above 0.1 percent weight by weight.

This page summarises official EU and UK sources for education. It is not legal or compliance advice, and the rules and lists change.

RoHS in brief

Restricted substanceMaximum level (UK government guidance)Where it can show up in plastics
Cadmium0.01%older pigments and stabilisers
Lead0.1%older pigments and stabilisers
Mercury0.1%rarely in plastics
Hexavalent chromium0.1%some older pigments; metal coatings
PBB and PBDE0.1% eachbrominated flame retardants
DEHP, BBP, DBP, DIBP0.1% eachphthalate plasticisers, mainly in flexible PVC

The European Commission's RoHS page names the same ten substances and states that products with an electrical or electronic component must comply unless specifically excluded. The "where it can show up" column is our general guide, not part of the law.

Homogeneous material

A Commission guidance document defines a homogeneous material as one that cannot be mechanically separated into different materials by unscrewing, cutting, crushing, grinding or abrasion. It gives the example of a single-plastic cover with no coating or inserts: the limits apply to that plastic. A painted or overmoulded part has several homogeneous materials, each judged separately, so the paint, insert and each resin matter.

REACH duties for articles

  • Inform customers. Article 33 requires suppliers of an article with a candidate list substance above 0.1 percent w/w to give recipients enough information for safe use, at least the substance name.
  • Answer consumers. On request, the same information must be given to a consumer free of charge within 45 days, as the Commission's REACH page also notes.
  • Notify in some cases. HSE's UK REACH guidance says producers and importers of articles must notify when the substance is above 0.1 percent w/w and totals more than 1 tonne per producer or importer per year, no later than six months after it is added to the candidate list. HSE says this mirrors EU REACH.
  • Two systems. HSE states that UK REACH and EU REACH operate independently, so a product sold in both markets must meet both.

Checklist for a moulded part

  1. Decide whether the product is electrical or electronic equipment; if so, RoHS applies to its plastic parts.
  2. Ask the resin supplier for a RoHS statement and a REACH candidate list statement for the exact grade.
  3. Ask the same of the colour masterbatch or pigment supplier, and of any paint, ink or insert supplier.
  4. Record the candidate list version each statement refers to; the list grows over time.
  5. Keep statements in the technical file and re-check when a grade or colour changes.

Educational summary of public EU and UK pages. It is not legal or compliance advice, and it is not a statement about any company's products.

Questions buyers ask

Is a plastic part "RoHS compliant" on its own?

RoHS applies to equipment, but compliance is built from the materials. A supplier statement for the resin and colourant is what supports the part.

Does the 0.1 percent REACH figure apply to the whole product?

The Article 33 duty is framed per article. For assembled products, ask an advisor how it applies to each component.

Are flame-retardant grades a concern?

Some older brominated flame retardants are restricted under RoHS. Ask for the RoHS statement for the specific flame-retardant grade.

Does REACH registration apply to me as a buyer of parts?

The Commission notes registration applies to substances above 1 tonne per year per company. Article buyers mainly deal with the information duties above.

Sources