Chemical regulations are an increasingly important factor in the metal powder supply chain. The European Union's REACH and RoHS regulations impose significant obligations on manufacturers, importers and downstream users of chemical substances -- including metal powders. Non-compliance can result in market access restrictions, legal penalties and reputational damage.
This article provides a practical overview of REACH and RoHS as they apply to metal powders, explains the key compliance requirements, and describes how MEPOSO ensures full regulatory compliance across its product range.
What is REACH?
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the European Union's comprehensive chemicals regulation, in force since 2007. It applies to all chemical substances manufactured in or imported into the EU in quantities of one tonne or more per year. Metal powders -- including copper, tin, zinc, nickel and their alloys -- fall within the scope of REACH.
Registration
Under REACH, manufacturers and importers must register their substances with the European Chemicals Agency (ECHA). Registration requires the submission of a technical dossier containing information on the substance's properties, uses, hazards and risk management measures. The level of detail required increases with tonnage: substances manufactured or imported at 10 tonnes or more per year require a Chemical Safety Report (CSR) with exposure scenarios.
For metal powders, registration typically covers the base metal substance (e.g., copper, CAS 7440-50-8) and any alloying elements. Alloys themselves are not considered substances under REACH but are treated as special preparations (mixtures) of their constituent metals.
Substances of Very High Concern (SVHC)
REACH identifies certain substances as SVHCs due to their carcinogenic, mutagenic, reprotoxic (CMR), persistent bioaccumulative and toxic (PBT), or endocrine-disrupting properties. SVHCs are placed on the Candidate List, and companies must notify ECHA and inform their customers if their products contain SVHCs above 0.1% by weight.
In the metal powder industry, the most relevant SVHCs include:
- Lead (Pb) and lead compounds: Lead is classified as reprotoxic and is on the SVHC Candidate List. Lead powder suppliers must communicate the SVHC status to downstream users.
- Cobalt and cobalt compounds: Several cobalt compounds are classified as CMR substances. While cobalt metal itself has a harmonised classification, it is used in some pre-alloyed powders.
- Nickel and nickel compounds: Nickel powder (respirable fraction) is classified as carcinogenic. Appropriate handling and exposure controls are required.
Authorisation and Restriction
Substances on the Authorisation List (Annex XIV) cannot be placed on the market or used without specific authorisation from the European Commission. The Restriction List (Annex XVII) imposes conditions or bans on the manufacture, marketing or use of certain substances. Metal powder users should regularly monitor these lists for any changes affecting their supply chain.
What is RoHS?
The Restriction of Hazardous Substances Directive (RoHS, Directive 2011/65/EU) restricts the use of specific hazardous substances in electrical and electronic equipment (EEE). While RoHS primarily targets finished electronic products, it has significant implications for metal powder suppliers whose products are used in electronics manufacturing.
Restricted Substances
RoHS restricts the following substances in EEE:
- Lead (Pb): maximum 0.1% by weight in homogeneous materials
- Mercury (Hg): maximum 0.1%
- Cadmium (Cd): maximum 0.01%
- Hexavalent chromium (Cr VI): maximum 0.1%
- Polybrominated biphenyls (PBB): maximum 0.1%
- Polybrominated diphenyl ethers (PBDE): maximum 0.1%
- Bis(2-ethylhexyl) phthalate (DEHP): maximum 0.1%
- Butyl benzyl phthalate (BBP): maximum 0.1%
- Dibutyl phthalate (DBP): maximum 0.1%
- Diisobutyl phthalate (DIBP): maximum 0.1%
For metal powders, lead and cadmium content are the most relevant RoHS parameters. Copper, bronze and brass powders used in electronic applications must be analysed for trace levels of these elements and certified as RoHS-compliant.
How REACH and RoHS Affect Metal Powder Users
If you purchase metal powders for use in manufacturing, REACH and RoHS create several obligations:
- Supply chain communication: You are entitled to receive Safety Data Sheets (SDS/MSDS) from your powder supplier, including information on hazards, safe handling, exposure scenarios and any SVHC content.
- Downstream user obligations: Under REACH, downstream users must ensure that their use of a substance is covered by the supplier's registration and exposure scenarios. If your use is not covered, you may need to notify ECHA or seek registration.
- RoHS declarations: If you manufacture or import electrical and electronic equipment into the EU, you must ensure all materials -- including metal powders -- comply with RoHS thresholds. Obtain RoHS compliance declarations from your suppliers.
- Record keeping: Maintain records of SDS, compliance declarations and any SVHC notifications for at least 10 years, as required by REACH.
How MEPOSO Ensures Compliance
MEPOSO takes regulatory compliance seriously and has implemented comprehensive systems to ensure our products meet all applicable requirements:
- Full REACH registration: All substances manufactured by MEPOSO in quantities above the REACH threshold are registered with ECHA. Our registrations cover all standard and foreseeable downstream uses.
- SVHC monitoring: We actively monitor the ECHA Candidate List and communicate any changes to our customers promptly. Products containing SVHCs are clearly identified and accompanied by appropriate documentation.
- RoHS compliance: Our standard copper, bronze and tin powders are manufactured from high-purity raw materials and routinely tested to confirm compliance with RoHS substance thresholds.
- Safety Data Sheets: We provide comprehensive SDS for all products, prepared in accordance with Regulation (EC) No 1907/2006 and available in multiple languages. SDS are updated whenever new information becomes available.
- Quality management: Our ISO 9001-certified quality management system ensures traceability from raw material to finished product, supporting full supply chain transparency.
- Technical support: Our regulatory affairs team is available to answer specific compliance questions and provide documentation needed for your own regulatory obligations.
Staying Compliant: Best Practices
Regulatory landscapes evolve continuously. ECHA regularly adds new substances to the SVHC Candidate List, and RoHS exemptions are periodically reviewed and may be withdrawn. To stay compliant, we recommend:
- Working with established, REACH-registered suppliers who proactively communicate regulatory changes
- Requesting updated SDS and compliance declarations at least annually
- Monitoring ECHA and EU Commission publications for changes to the Candidate List, Authorisation List and Restriction List
- Implementing internal processes to assess the impact of regulatory changes on your products and supply chain
- Training purchasing and quality staff on REACH and RoHS requirements
MEPOSO is committed to being a transparent and reliable compliance partner. Visit our Service & Support page to learn more about our technical assistance, or contact us to request SDS, compliance declarations or specific regulatory documentation for our products.