REACH and RoHS Compliance for Machinery Builders: SVHC Candidate List, SCIP Database and RoHS 10 Substances
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 Substance | Maximum Permitted Concentration (by weight) | Common Industrial Machinery Applications | Applicable 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.