RoHS and REACH for Springs and Stampings: A Supplier Compliance Primer
European and increasingly global buyers require RoHS and REACH statements with every shipment. For spring and stamping suppliers, compliance is largely a solved problem — if the paperwork chain is real.
RoHS in metal parts: where the risk actually is
The base steels, stainless grades, and copper alloys used for springs are inherently free of RoHS's core restricted substances at regulated levels, with legacy exceptions:
- Hexavalent chromium — the big one: old yellow/olive chromate conversion coatings. Modern trivalent passivates replace them fully (plating guide)
- Lead — in some legacy free-machining brasses and old solders; specify lead-free alloys where copper alloys appear
- Cadmium — obsolete plating; simply never allow it
A compliant spring is therefore: standard wire + trivalent-passivated or flake coating + lead-free incidental materials. This is default practice in serious Taiwanese factories today.
REACH: the moving list
REACH's SVHC (Substances of Very High Concern) list updates twice yearly. Metal parts rarely contain SVHCs above the 0.1% w/w threshold, but the *declaration obligation* stands regardless. What good suppliers provide:
- Current SVHC declaration referencing the list version and date
- Material and coating composition data supporting it
- Update commitment as the list evolves
What to require from your supplier
- RoHS declaration naming the directive (2011/65/EU + amendments) per part number
- REACH SVHC declaration with list date
- Coating process specs proving trivalent chemistry
- For high-scrutiny industries: third-party XRF or lab reports on request
Formosa Spring provides all four with export documentation — flag compliance requirements in your RFQ and they are built into the quality plan from day one.
Frequently Asked Questions
Are stainless steel springs automatically RoHS compliant?
Effectively yes — the alloying elements of 302/304/316/17-7PH are not restricted substances. Documentation is still required; "automatic" compliance still needs a signed declaration.
What replaced yellow zinc chromate?
Trivalent passivates with topcoats now match old hexavalent performance, including yellow-iridescent appearance where cosmetics matter. There is no technical reason to accept hex chrome today.
Do RoHS and REACH apply to parts sold outside Europe?
Formally they are EU regulations, but global OEMs commonly flow them worldwide, and similar rules exist elsewhere (China RoHS, UK REACH). Building compliant-by-default parts is cheaper than managing regional variants.