Somebody in purchasing sends a form asking whether your packaging is REACH compliant and RoHS compliant, and it comes back yes. The question worth asking is what that yes actually covers, because the answer varies enormously and almost nobody checks.
What the two things are
REACH is the EU regulation on registration, evaluation, authorisation and restriction of chemicals. Among other things it maintains a list of substances of very high concern, and articles containing those above a threshold carry obligations. Whether your spool has any obligations depends on what substances are actually in it above 0.1% by weight, which is a composition question.
RoHS restricts specific hazardous substances in electrical and electronic equipment. If a PP spool is not a component of electrical equipment, RoHS may not apply to it directly at all — though many customers ask anyway, particularly if the spool ships with electronic product on it.
Both are real legal regimes with real requirements, and both are frequently answered with a generic document that does not engage with either.
What we can say honestly
Things a polymer fabricator can actually substantiate:
- The base polymer, and whether the specific resin supply chain has a registration covering the intended use
- Whether specified SVHCs above threshold are present, based on the composition we know and what our material suppliers tell us
- Whether we intentionally added any of the RoHS-restricted substances
- Material identity, so that you can do your own assessment
What we cannot honestly say
- That the finished article is certified compliant — these are not certification schemes for this type of product, and a document claiming certification should be treated with suspicion
- Anything about substances we did not add and do not test for. Unintentional trace content is a different question, requiring testing we have not done.
- Anything about your finished assembly, which is your obligation, not ours
- Anything covering another supplier’s product just because it looks similar
The recycled content complication
Worth flagging because it interacts with the next article in this series. Recycled material has a less well-defined composition history than virgin resin. If you are using regrind or recycled content and also making substance declarations, those two things need reconciling — and the honest answer may be that the declaration is weaker than for virgin material.
This is not a reason to avoid recycled content. It is a reason not to make both claims carelessly at the same time.
What to actually ask for
Instead of “please confirm REACH compliance”, which gets a stock answer:
- Declaration of the base polymer and any additives the supplier knows about
- An SVHC statement referencing the current list version and dated — the list updates regularly, so an undated statement is meaningless within a year
- Confirmation the supplier will notify you of composition changes — which is the genuinely valuable commitment, and belongs in your quality agreement
- Test reports where testing genuinely exists, with scope and method stated
Reading what comes back
A useful heuristic: does the document say what it is based on? A statement citing material declarations, a list version and a date suggests somebody did something. A statement reading “all products comply with REACH and RoHS” with no further detail is a form letter, and it will not help you if anyone ever genuinely asks.
A note on geography
These are EU regulations, but they get asked about globally because many customers have EU market exposure or operate a single global compliance standard. Similar substance regimes exist in other jurisdictions. Which regimes apply to you depends on where you sell, which is your question rather than your supplier’s.
Our position
For our hollow board spools we will tell you what the material is, what we know about its composition, and what we can substantiate. Where the honest answer is “we have not tested for that”, we will say it, because a confident unsupportable claim in your compliance file is a liability you inherit.
We are not going to write you a certificate for something that does not have a certification scheme.