Industry

REACH and RoHS Compliance for Machinery Builders: SVHC Candidate List, SCIP Database and RoHS 10 Substances

Dr. Arthur Campbell (Industrial Compliance)
September 18, 2026
10 min min read
REACH and RoHS Compliance for Machinery Builders: SVHC Candidate List, SCIP Database and RoHS 10 Substances
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Detailed compliance manual for machinery manufacturers: Article 33 SVHC notifications, ECHA SCIP dossiers, and RoHS 10 substance restrictions.

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CHEMICAL COMPLIANCE · REACH & ROHS

REACH and RoHS Compliance for Machinery Builders: SVHC Candidate List, SCIP Database and RoHS 10 Substances

DIRECT REGULATORY ANSWER (60 SECONDS):

What are the mandatory REACH and RoHS compliance duties for industrial machinery manufacturers? Industrial machinery builders must comply with both REACH (Regulation (EC) 1907/2006) and RoHS Directive (2011/65/EU as amended by 2015/863). Under REACH Article 33, manufacturers must notify commercial customers within 45 days if any component article contains a Substance of Very High Concern (SVHC) from the ECHA Candidate List in concentration exceeding 0.1% weight by weight (w/w), and submit a formal dossier to the ECHA SCIP database under the Waste Framework Directive. Under RoHS, all electrical and electronic components incorporated into machinery must not exceed strict maximum concentration values for 10 restricted hazardous substances (including Lead, Mercury, Cadmium, Hexavalent Chromium, and four phthalates: DEHP, BBP, DBP, DIBP).

Detailed compliance manual for machinery manufacturers: Article 33 SVHC notifications, ECHA SCIP dossiers, and RoHS 10 substance restrictions.

Technical Specifications & Regulatory Comparison Matrix

RoHS Restricted SubstanceMaximum Permitted Concentration (by weight)Common Industrial Machinery ApplicationsApplicable Exemptions
Lead (Pb) 0.1% (1,000 ppm) Machining brass alloys, bronze bushings, solder joints Exemption 6c (copper alloy up to 4% lead)
Cadmium (Cd) 0.01% (100 ppm) Surface plating on electrical contacts, specialty plastics Virtually zero exemptions in new machinery
Hexavalent Chromium (Cr VI) 0.1% (1,000 ppm) Passivation layers on galvanized steel fasteners & panels Transition to trivalent chromium (Cr III) required
Mercury (Hg) 0.1% (1,000 ppm) Relays, level switches, legacy fluorescent backlight HMIs Strict phase-out; LED / electronic solid-state only
Phthalates (DEHP, BBP, DBP, DIBP) 0.1% (1,000 ppm) Flexible PVC cable insulation, pneumatic hoses, seals Must utilize non-phthalate plasticizers

1. The "Once an Article, Always an Article" (O5A) Principle

Under the 2015 European Court of Justice ruling (Case C-106/14), the 0.1% w/w threshold for SVHCs applies to each individual component article within a machine, NOT to the total weight of the finished complex machine. For example, if a tiny brass fitting contains 2% lead, that fitting triggers REACH Article 33 and SCIP submission, even though the fitting represents 0.001% of the total 5-ton machine.

2. ECHA SCIP Database Registration Workflows

Under Directive 2008/98/EC Article 9(1)(i), suppliers of articles containing SVHCs above 0.1% must submit full dossiers to the ECHA SCIP database. The dossier includes product identification, material category, SVHC concentration range, and safe use instructions. SCIP numbers must be linked downstream.

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Frequently Asked Questions (FAQ)

Are Large-Scale Fixed Installations (LSFI) exempt from RoHS?

Yes. Category 11 electrical equipment part of Large-Scale Stationary Industrial Tools (LSSIT) or Large-Scale Fixed Installations (LSFI) can be exempt from RoHS Directive scope. However, REACH SVHC obligations and SCIP submissions still apply without exemption.

How can a machinery builder collect REACH/RoHS declarations from 500 suppliers?

Industry best practice relies on IEC 62474 material declaration declarations or automated material compliance software rather than unstructured PDF questionnaires.

📥 Lead Magnet: Machine OEM REACH SVHC & RoHS Compliance Matrix

Audit your Bill of Materials (BOM) against Candidate List SVHCs, RoHS 10 exemptions (like 6c for brass), and SCIP notification triggers.

Download Compliance Template →

Editorial note: Last updated September 2026. Reviewed by the Igera Industrial Compliance Committee.

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