Can a RoHS report replace REACH?

No. RoHS judges ten substances per material; REACH passes information on 240-plus SVHCs per article weight. One case needs both.

Can a whole case be tested once for RoHS?

No. The unit is the homogeneous material, and a blended sample dilutes an exceedance; twelve materials ship with one report each.

Is an SVHC below 0.1% irrelevant?

The threshold runs on whole-article weight, so below 0.1% w/w no SCIP notification is due, but keep the calculation; the list changes twice a year.

Must a report be replaced every year?

No legal expiry exists. Unchanged materials keep it valid; a new material, masterbatch, plating or supplier triggers a re-run in about 5 working days.

Why do zinc-plated parts fail on hexavalent chromium?

Passivation decides it: trivalent passes, hexavalent fails, and the two look identical. Specify the type, then screen total chromium by XRF.

Exporting to the EU: RoHS and REACH for Cases

Quick answer: RoHS restricts ten substances and judges each homogeneous material against its own limit, 1000 ppm for lead, mercury, hexavalent chromium and four phthalates, 100 ppm for cadmium. REACH instead demands information on more than 240 SVHCs above 0.1% w/w.

Ten Substances, Judged Per Homogeneous Material
REACH Runs on Different Logic: SVHC and Thresholds
Testing Route: XRF Screens, ICP and GC-MS Confirm
The Document Pack: DoC, Reports, BOM, Traceability
Where Failures Cluster
When a Report Must Be Re-run
FAQ

1. Ten Substances, Judged Per Homogeneous Material

RoHS, Directive 2011/65/EU, lists ten restricted substances and judges them per homogeneous material, not per case. One injection-moulded case breaks down into 12 homogeneous materials: PP body, masterbatch, ABS latches, hinges, plated screws, gasket, PU foam, print ink, label adhesive, webbing, rivets and a buckle. Weighing the whole case and testing it once proves nothing.

Keep the arithmetic straight: 0.1% is 1000 ppm, 0.01% is 100 ppm, and only cadmium sits at 100 ppm. A reading of 0.008% means 80 ppm, 20 ppm of headroom, a figure common in regrind.

Substance	Limit	Typical source on a case
Lead, mercury	1000 ppm	Masterbatch, regrind, plating, salvaged parts
Cadmium	100 ppm	Red and yellow pigments, plating
Hexavalent chromium	1000 ppm	Zinc passivation, webbing tanning
PBB, PBDE	1000 ppm	Flame-retardant parts in regrind
Four phthalates	1000 ppm each	Soft compounds, inks, label adhesive

The last row covers DEHP, BBP, DBP and DIBP, added in 2015 and extended to all equipment categories in 2019. A case carries no current, so it falls inside the directive only as housing or an instrument box. The verdict follows the worst material: eleven of 12 pass and one plating reads 1200 ppm, the case fails.

2. REACH Runs on Different Logic: SVHC and Thresholds

REACH, Regulation (EC) 1907/2006, sets no fixed limit table; it governs information. The SVHC candidate list has passed 240 entries and the trigger is 0.1% w/w of the finished article, not of a homogeneous material. The same case splits 12 ways under RoHS, whole under REACH.

RoHS submission case: black body tilted forward, two red latches clamped on the front rim, handle folded down, hinge bosses behind

Crossing it brings three duties: Article 33 safe-use information downstream, answered within 45 days; a SCIP notification per article, one record per model; and a notice under Article 7(2) above 1 tonne a year.

Take 0.1% on the worst case. A 3.2 kg case with a 180 g gasket carrying 0.5% of an SVHC reads 0.028%, under the trigger; the same gasket in a 1.1 kg case reads 0.082%, and one size smaller crosses the line.

That is why REACH paperwork is heavier: RoHS is one ten-item report, REACH a bill of materials checked against 240-plus entries.

3. Testing Route: XRF Screens, ICP and GC-MS Confirm

Export lots run two tiers: XRF on site at 30 seconds per point, cadmium detection near 20 ppm, clearing 12 materials inside an hour; then ICP-OES for lead, cadmium and chromium, GC-MS for flame retardants and phthalates.

Item	Method	Detection limit	Where it sits
Pb, Cd, total Cr	XRF screening	15–20 ppm	Incoming screening
Pb, Cd, Cr	ICP-OES	2 ppm	Confirming an exceedance
Hexavalent chromium	Spectrophotometry	1 ppm	Passivation disputes
PBB, PBDE	GC-MS	50 ppm	Flame-retardant parts
Four phthalates	GC-MS	50 ppm	Soft compounds and inks

Screening needs a safety band: below 30% of the limit passes, 30%–70% is re-screened, above 70% goes to ICP. XRF suffers matrix effects, and thickness shifts a reading by 20%.

Mixed testing is the trap: one nibble from each of 12 materials in a single sample dilutes the reading twelvefold, so a 1200 ppm plating reads 100 ppm. Confirmation runs material by material.

4. The Document Pack: DoC, Reports, BOM, Traceability

An EU customer wants a pack that lines up: declaration of conformity, third-party reports, a bill of materials with supplier declarations, and batch traceability, all pointing at one model.

RoHS teardown candidate: black case standing face-on, red latches gripping both ends of the handle, one moulded mark in each lid corner

Document	Issued by	Covers	Refresh
Declaration of conformity	Manufacturer	Model, directive clauses	On model change
Test report	Third-party lab	One homogeneous material	Annual
Bill of materials	Manufacturer	Every material and supplier	On material change
Batch record	Manufacturer	Part number, lot, machine, date	Every lot

The DoC names the directive, models, standards and a signatory; the manufacturer signs it, not the lab. A report proves the state of the sample on the day, showing material, method and limit.

The BOM bridges report and hardware: one part number, one supplier, one report number per material. Changing supplier without changing the part number breaks the link.

Traceability works backwards: when a customer complains, the masterbatch supplier, machine and shift surface within 2 hours, or the recall scope becomes the model.

5. Where Failures Cluster

Regrind leads: salvaged material drags in battery shells, solder and old cable, pushing lead to 3 times the limit; structural parts still need a report.

Masterbatch comes second: cadmium reds and yellows still circulate, and at 2% loading a batch carrying 5000 ppm cadmium pushes the moulding to 100 ppm.

Flame retardants come third: old flame-retardant parts in regrind bring PBDE, and decaBDE was restricted in 2008 while recycling loops keep recirculating it. A flame-retardant case needs a report for the masterbatch, never the base resin.

Plating comes fourth: zinc parts passivated with hexavalent chromium fail outright, trivalent passes, and the two look identical. Nylon webbing and EPDM gaskets bring azo dyes and polyaromatic hydrocarbons, which sit under Annex XVII of REACH.

6. When a Report Must Be Re-run

Reports carry no stated validity; a year is the habit. A re-run follows change: a new resin grade, masterbatch, plating process, or supplier at the same grade.

Cases that need no re-run: a new tool, a colour shift without a masterbatch change. The test is whether the material changed.

A RoHS audit fails on reports that miss the BOM more often than on an over-limit reading; keep part, report and lot numbers in one table.

Conclusion

Two tracks run for an EU-bound case. RoHS takes 12 materials against ten substances, cadmium under 100 ppm, the other nine under 1000 ppm. REACH weighs the whole case for SVHCs and, above 0.1% w/w, triggers a customer notice and a SCIP record. A DoC, reports, BOM and lot records must point at one model.

This article discusses only the container (case body) side of specifications and design intent, and does not cover any handling, loading or use of the contents.