Can a six-item case rohs report serve as a ten-item one?

No. It omits DEHP, BBP, DBP and DIBP at 1000 ppm each, and soft gaskets and inks are exactly where those appear.

How many homogeneous materials does one case yield?

A 520 mm by 420 mm by 210 mm moulded case yields 14: lid, base, latch, pin, hinge, rivet, gasket, adhesive, foam, ink, label face, label glue, valve and foot pad.

Is a passing XRF reading enough to ship?

No. XRF reads total elements and cannot detect Cr(VI). Any part above 70% of its limit goes to ICP-OES or GC-MS, with 3 parts per lot.

Does an expired report mean full re-testing?

Judge by material change, not by date. If materials and suppliers are unchanged the report carries over; a new masterbatch or gasket compound re-tests that part.

Case Rohs Report: 6 vs 10

Quick answer: A six-item case rohs report covers six substances only, while the ten-item version adds four phthalates at 1000 ppm each, so it cannot replace it.

Where the six-item and ten-item report differ
How homogeneous materials get split
Detection limits against decision limits
Linking XRF screening to confirmation
Report validity and lot traceability
FAQ

1. Where the six-item and ten-item report differ

The six-item list dates from 2006: lead, mercury, cadmium, hexavalent chromium, PBB and PBDE. Directive (EU) 2015/863 added DEHP, BBP, DBP and DIBP in June 2015, enforced them from 22 July 2019 and extended them to medical devices on 22 July 2021. The substance count on page one decides the work that follows.

Item	Six-item report	Ten-item report
Restricted substances	6	10
Phthalates	none	4, at 1000 ppm each
Legal basis	2011/65/EU	2011/65/EU plus 2015/863

Four extra phthalates push the soft parts onto separate lines: gasket compound, screen-print ink and foam adhesive each need their own sample, so the material count rises by two.

Phthalates sit in predictable places: a PVC gasket needs plasticiser with DEHP at 20–40% of the compound, and inks and adhesives carry residues too. On a 42 L case the gasket read 1800 ppm DEHP, and 38 ppm after switching to TPE.

Six items still satisfy some buyers: EU-bound electronic enclosures have required ten since 2019, while mechanical tool boxes sometimes pass on six.

2. How homogeneous materials get split

A homogeneous material cannot be separated mechanically. A 520 mm by 420 mm by 210 mm moulded case yields 14 samples: lid and base are both PP but differ in colour, the latch is POM while the pin is 304 stainless, and the gasket and its adhesive film are separate submissions.

Case rohs report teardown: closed navy case angled on a steel shelf, moulding seam along the lid joint, one latch with a round pressure valve

Part	Material	Phthalate risk	Splitting rule
Lid, base	PP	low	one sample per colour
Gasket	EPDM or PVC	high	adhesive kept separate
Latch, pin	POM, 304 stainless	low	never merged
Screen-print ink	solvent based	medium	scraped separately

Splitting errors outnumber failing readings. Merge latch and pin and the chromium from the pin is diluted by POM, giving a clean number; dissolve the gasket with its adhesive and 1800 ppm DEHP reads as 700 ppm. Each line needs an ID, material, colour, location and weight share.

No averaging applies. One of 14 samples above its limit fails the case, and rework touches that part alone.

3. Detection limits against decision limits

Ten items use two thresholds: cadmium at 0.01%, or 100 ppm, and the rest at 0.1%, or 1000 ppm. Figures may print as 0.1%, 1000 ppm or 1000 mg/kg, so normalise units first.

Method	Substances	Detection limit	Role
XRF	Pb, Cd, total Cr, Br	15–30 ppm	lot screening
ICP-OES	Pb, Cd, total Cr	2 ppm	confirmation
ICP-MS	Pb, Cd	0.1 ppm	near-limit dispute
Spectrophotometry	Cr(VI)	1 ppm	plating, passivation
GC-MS	four phthalates	10–20 ppm	soft parts, inks

ND without a detection limit is unusable: below 10 ppm it leaves a 100-fold margin to the line, below 50 ppm only 20-fold.

Near-limit readings need a guard band. At 920 ppm against a 1000 ppm limit the 95% interval touches the line, so we re-run and confirm by a second method; a 15% spread between runs re-samples the lot.

Cadmium leaves the least room: a 5000 ppm cadmium red dosed at 2% lands the part at exactly 100 ppm, so red, yellow and orange parts get their own line.

4. Linking XRF screening to confirmation

A handheld XRF needs 30 s per spot and 3 spots per part, covering 400 parts in an 8-hour shift. It reads total elements, cannot see hexavalent chromium and cannot separate PBB from PBDE congeners, so it only screens.

Case rohs report samples: four open cases on a wood-grain bench, blue with slotted foam, black with an orange-capped cylinder, red with metal fittings

Set gates on the limit: below 30% release, 30–70% re-test two more spots, above 70% send out. Plastic under 2 mm reads 10–20% low, and plating under 5 μm lets the beam reach the substrate.

Confirmation is method-specific: ICP-OES for lead, cadmium and total chromium at 2 ppm, GC-MS for the four phthalates after extraction, alkaline extraction with spectrophotometry for Cr(VI) at 1 ppm. Three parts per lot go out, results in 5 working days.

The classic error is reading total chromium as Cr(VI): a zinc-plated part can show 800 ppm total with zero Cr(VI), while 60 ppm total can hide 40 ppm Cr(VI) in the passivation layer.

5. Report validity and lot traceability

No regulation sets an expiry date; the trade convention is 12 months, and large buyers write that age limit into contracts. A new resin grade, masterbatch supplier, plating process or EPDM-to-PVC swap triggers re-testing.

A new mould, wall thickness revision or different press leaves the composition intact, so the report carries over while the BOM needs a version line.

Three fields bind a report to a lot: part number, BOM revision and month of manufacture. Once the masterbatch supplier changes, an old file no longer covers new production, so we keep 3 parts per lot for 24 months.

Purchase order clauses save time: 10 substances, every homogeneous material with its ID and limit, ND qualified, issue date within 12 months, and 15 days notice before any change.

Conclusion

When a case rohs report arrives, check nine fields in order: report number and issue date inside 12 months; legal basis naming 2011/65/EU with 2015/863; 10 substances including the four phthalates; all 14 homogeneous materials with ID, material, colour and location; limits written as 0.01% for cadmium and 0.1% for the rest; methods separating XRF screening from ICP-OES and GC-MS confirmation; ND qualified by a detection limit; photos matching the model and BOM revision; signature and accreditation mark on the last page. One missing field is a reissue request. Then bind the file to the lot: the report covers the submitted sample only, and an old file dies with a material change. Substance count, detection limits, 12-month age and change notice belong in the purchase order.

This article discusses container-side specifications and design implications only, and does not cover any handling, loading or use of the contents.