Compliance is a supply-chain question. Whether a custom part needs RoHS or REACH documentation depends on what the product is, where it sells, and what the materials and finishes contain—and the answer comes from the supply chain, not from a single certificate. This guide covers the common compliance requirements, what documents to request, and how to put the requirement in the RFQ.
Compliance Is a Supply-Chain Question
A part's compliance is not a property of the part alone; it is a property of the material, the finish, and the supply chain that produced it. The question is not "is this part RoHS compliant" but "do the materials and finishes in this part meet the restrictions, and can the chain prove it?"
That framing drives the process: the buyer states the requirement, the supplier verifies the materials and finishes, and the documentation connects them. The compliance evidence is only as strong as the chain behind it.
The compliance chain starts at the material. The alloy's composition, the coating's chemistry, and the additive's substances are the chain's inputs, and each is verified against the restriction; the material verification is the chain's foundation. The buyer should trace the material evidence with the supplier, because the compliance is built from the inputs. The inputs that are verified are the ones that are trusted, and the trust is the compliance's strength.
The compliance chain extends to the supplier's supplier. The material is purchased from the upstream mill or distributor, and the certificates travel down the chain; the buyer should confirm the upstream evidence with the supplier, because the chain's weakest link is the limit. The chain that is traced is the one that is complete, and the completeness is the compliance's proof.
RoHS: What It Restricts and Who Needs It
RoHS restricts hazardous substances—lead, mercury, cadmium, and others—in electrical and electronic products sold in the EU and many other markets. Custom parts that go into such products need RoHS-compliant materials and the documentation to prove it.
The practical questions are the product and the part: does the finished product fall under RoHS, and do the part's materials and finishes meet the limits? The supplier confirms the material grades and the finishes against the restrictions.
The RoHS scope is a product and part decision. The finished product's market and category set the requirement, and the part's materials and finishes are checked against the restricted substances; the scope is the requirement's boundary. The buyer should confirm the part's RoHS status with the material and the finish data, because the status is the data's conclusion. The data that is confirmed is the one that is declared, and the declaration is the one that is accepted.
The RoHS exemption is part of the assessment. Some applications carry exemptions for specific substances, and the exemption must be documented and justified; the buyer should confirm the exemption's applicability with the compliance team. The exemption that is documented is the one that is valid, and the validity is the one that is accepted.
The RoHS decision starts with the product's market. A product sold into the European market, or supplied into a supply chain that reaches it, carries the RoHS requirement, and the restricted substances apply to the homogeneous materials of the part; the buyer should determine the market first, because the compliance work follows the destination.
The restriction list is the substance map of the directive. The heavy metals and the flame retardants are limited to defined concentration thresholds, and the supplier's declaration and the test evidence support the part's position; the buyer who sends the part into a regulated market should confirm the documentation with the RFQ rather than discover the gap at the customer audit.
REACH: Registration and Communication
REACH regulates chemicals in the EU, with registration for substances of very high concern (SVHCs) and communication obligations down the supply chain. Custom parts trigger the communication duty where restricted substances appear above the thresholds.
The practical note is that REACH is a communication and registration system, not a simple pass-fail. The buyer requests the relevant declarations and the supplier confirms the substances in the materials and finishes.
The REACH communication is a substance-by-substance check. The candidate list of substances of very high concern is checked against the part's materials and finishes, and the presence above the threshold triggers the communication; the check is the declaration's basis. The buyer should request the REACH declaration with the material data, because the communication follows the substances. The declaration that is based is the one that is correct, and the correctness is the one that complies.
The REACH obligation is a supply-chain duty. The supplier communicates the substance information down the chain, and the buyer passes it to the product's users; the duty is a chain of communication. The buyer should confirm the supplier's REACH process, because the obligation flows with the product. The process that is in place is the one that is met, and the meeting is the one that is compliant.
REACH is a communication and registration system that runs alongside the product's material composition. The substances of very high concern travel through the supply chain with their information, and the supplier communicates what it knows about the materials it processes; the buyer should ask for the available declaration and treat the missing information as a gap to close, not a fact to assume.
The REACH information chain is only as strong as its weakest link. The raw material supplier, the processor, and the assembler each pass the substance information forward, and a break in the chain leaves the buyer without the evidence; the request for the material-level declarations should be part of the sourcing qualification, not an afterthought at shipment.
Compliance Documents You Can Request
The documents follow the requirement: RoHS certificates or declarations for the restricted substances, REACH declarations for the SVHCs, and material certificates that tie the grades to the compliance. The documentation set is defined by the product's market.
6CProto states that RoHS compliance certificates are available on request. The buyer's practice is to name the specific documents in the RFQ—certificate type, substance list, and material scope—so the supplier can confirm and provide them.
The compliance document's content is checked against the product. The certificate names the substance list, the material scope, and the standard, and the buyer verifies the scope matches the part; the content is the document's value. The buyer should check the certificate's scope, because a generic certificate is not a part-specific proof. The certificate that is scoped is the one that is valid, and the validity is the one that is accepted.
The compliance document's format is the buyer's usability. The certificate and the declaration are readable, dated, and tied to the part and the batch, and the records are filed for the audit; the format is the document's utility. The buyer should specify the format with the request, because the compliance records serve the audits. The format that is usable is the one that is kept, and the kept records are the ones that serve.
The document set for compliance is a stack of evidence with different weights. The material certificates trace the raw material, the RoHS declaration states the part's position, and the test report provides the laboratory evidence; the buyer should specify which documents the order must include so the supplier prices and produces the set.
The declaration and the test report are not interchangeable. The declaration is the supplier's statement of position, and the test report is the evidence behind it; a buyer who accepts a declaration without the supporting material data is accepting a claim, and a buyer who requests both has a compliance file.
How to Put Compliance in an RFQ
Compliance belongs in the RFQ, not in the follow-up. The requirement states the regulation, the substance list, the material and finish scope, and the document format. The supplier prices the verification and delivers the documents with the parts.
The practice is to name the standard and the scope explicitly: "RoHS compliance required for the specified materials and finishes, with certificates accompanying the order." The requirement that is named is the requirement that is met.
The compliance requirement belongs in the RFQ's document section, next to the drawings and the material spec. The buyer names the directive, the document set, and the acceptance point, and the supplier quotes the compliance work with the order; the compliance requirement that arrives after the order is a change order in every sense.
The RFQ should also name the acceptance stage. The compliance documents are reviewed with the first article, and the batch is released only when the file is complete; the buyer who ties the documents to the payment milestone gets the evidence before the money moves.
Limits of Supplier Declarations
Supplier declarations have limits: they confirm what the supplier knows about its materials and processes, and they rely on the upstream certificates. The declaration is evidence, not a guarantee, and the buyer's verification—testing where the risk demands it—completes the chain.
The practical note is to match the evidence to the risk: declarations for standard materials, certificates for the critical ones, and testing where the consequence justifies it. The compliance program is proportionate to the product.
The compliance record's retention is part of the program. The certificates, the declarations, and the test data are retained for the product's life and the regulatory window, and the records are retrievable; the retention is the program's memory. The buyer should set the retention with the program, because the records serve the future audits. The retention that is set is the one that is available.
The compliance program's review is the update loop. The substance lists, the regulations, and the material data change, and the program is reviewed and updated; the loop is the compliance's currency. The buyer should review the program periodically, because the compliance follows the current rules. The review that is run is the one that stays current.
The declaration's limit is its scope. The supplier declares what it knows about the materials and the processes it controls, and the deep substance history of the raw material belongs to the upstream chain; the buyer should read the declaration's scope clause the way a contract clause is read.
The limitation is also a planning input. The parts that need full substance evidence should be identified early so the material sourcing and the testing are scheduled; the buyer who plans around the limits gets a compliance path, and the buyer who ignores them gets a shipment block.
Request Compliance Documentation
Compliance is a supply-chain question answered with the right documents. The requirement is named in the RFQ, the materials and finishes are verified, and the certificates and declarations accompany the parts.
The quote-reading guide (CT01) covers the documentation lines in a quote. When you request a quote, state the compliance requirements and the documents, and the engineering team can confirm the materials and the certificates.
The compliance request's timing is part of the order. The certificates and the declarations are requested with the RFQ, so the compliance is priced and scheduled; the timing is the document's availability. The buyer should request the documents with the order, because the compliance is part of the deliverable. The request that is early is the one that is met.
The compliance evidence's acceptance is the final check. The certificates and the declarations are reviewed against the scope, and the parts are accepted with the evidence; the acceptance is the program's gate. The buyer should check the evidence at the receipt, because the compliance is delivered with the parts. The check that is done is the one that closes.
Conclusion
Compliance is a supply-chain question. RoHS restricts substances in electronics, REACH communicates them in the EU, and the documents tie the materials and finishes to the requirements. The RFQ names the requirement, and the evidence follows the parts.
The next step is to identify your product's market and regulations, name the documents in the RFQ, and request the compliance evidence with the order.
The compliance evidence's verification is part of the acceptance. The certificates and the declarations are checked against the scope and the batch, and the parts are accepted with the evidence; the verification is the compliance's gate. The buyer should verify the evidence at the receipt, because the compliance is delivered with the parts. The gate that is run is the one that protects.
The compliance program's supplier list is part of the procurement. The suppliers are assessed for the compliance capability, and the qualified ones carry the certificates; the list is the procurement's filter. The buyer should assess the suppliers with the compliance in mind, because the evidence follows the capable supplier. The list that is qualified is the one that is trusted.
FAQs
Does my custom part need RoHS documentation?
It depends on the product and the market. Parts that go into electrical or electronic products sold in restricted markets need RoHS-compliant materials and the documentation to prove it.
What is the difference between RoHS and REACH?
RoHS restricts hazardous substances in electrical and electronic products; REACH regulates chemicals in the EU with registration and communication obligations. The part's product and market set the requirements.
What compliance documents should I request?
RoHS certificates or declarations, REACH declarations where relevant, and material certificates that tie the grades to the compliance. Name the documents in the RFQ.
How strong is a supplier declaration?
It confirms what the supplier knows about its materials and processes, relying on upstream certificates. It is evidence, not a guarantee—test where the risk justifies it.