REACH Compliance for Precision Metal Parts
If you manufacture or sell precision metal parts to customers in Europe, you have probably encountered the term REACH. It stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. The regulation applies to chemical substances manufactured in or imported into the European Union.
For a company that makes precision metal components, understanding how REACH applies to your parts is not always straightforward. The rules treat substances, mixtures and articles differently. A precision metal part usually falls into the category of an “article” under the regulation. That classification determines what obligations you have and what information you need to provide to your customers.
What Counts as an Article Under REACH
The regulation defines an article as an object that during production is given a special shape, surface or design that determines its function to a greater degree than its chemical composition. In plain language, if the shape of the part matters more than what it is made of, it is an article.
Precision metal parts meet this test easily. The shape and surfaces are created through machining, etching or other manufacturing processes. The dimensions and geometry are specified by the customer to perform a particular function. The raw material alone, whether it is stainless steel, aluminum or a specialty alloy, would not do the job without the final shaping. That is what makes a precision machined component an article under REACH.
The Article Exemption and What It Means
Because most precision metal parts qualify as articles, the main obligation for registration does not apply to the part itself. Registration is required for substances on their own or in preparations and for substances contained in articles only if they are intended to be released under normal conditions of use. A machined metal part is not releasing substances during its normal use. The metal is stable.
This is the core of the article exemption. If your part does not contain any substances that are meant to be released and it holds its shape throughout its service life, the registration requirements of REACH do not directly apply to your finished component. The raw material suppliers are the ones who handle the registration of the metal alloys.
Substances of Very High Concern (SVHC)
The article exemption does not mean you have no obligations. Under Article 33 of the REACH regulation, any supplier of an article that contains a Substance of Very High Concern above a concentration of 0.1 percent weight by weight has an obligation to inform their customers. This applies if the substance is on the candidate list maintained by the European Chemicals Agency.
Lead is a common example. Lead is used in certain copper and aluminum alloys to improve machinability. If your precision metal part contains a leaded alloy and the lead concentration exceeds 0.1 percent, you must provide information to your customer. The communication requirement exists even though the lead is safely bound within the metal matrix and is not released during normal use.
Communication and the SCIP Database
When you supply an article containing a candidate list substance above the threshold, you need to give your customer enough information to use the article safely. This usually involves providing a safety data sheet or a specific declaration. The information must include the name of the substance.
In addition to communicating with your direct customer, there is a reporting obligation to ECHA. The SCIP database, which stands for Substances of Concern In articles as such or in complex objects, is where companies submit information about articles that contain candidate list substances above the threshold. This database was established under the Waste Framework Directive to support waste treatment and recycling.
What This Means for a Precision Metal Parts Manufacturer
If you are a manufacturer like ChemTecUSA, which produces precision etched components, your first step is to understand the materials you use. You need to know the exact composition of the alloys and any plating or surface treatments applied to your parts. If any candidate list substance is present above 0.1 percent, you need a plan for providing the required notifications and communications.
You also need to pay attention to emerging regulations. There is an ongoing proposal to restrict per- and polyfluoroalkyl substances under REACH. That proposal, published in August 2025, considers a ban on PFAS with some time-limited derogations for specific applications. While this proposal is still under discussion, it points to a trend of increasing restrictions on certain substances. Staying informed about these changes helps you anticipate future compliance requirements.
Practical Steps for Compliance
Start by reviewing the material certifications from your suppliers. Ask for declarations that confirm the composition of the metals and coatings you use. Check the candidate list of SVHC substances on the ECHA website. If you use any alloy that contains lead, cobalt, nickel or other listed substances, determine the concentration in your specific alloy.
Prepare your communication documents if your parts contain candidate list substances above the threshold. You might need a safety data sheet that meets EU REACH requirements, which includes proper ingredient disclosures. Your customer may also ask for a confirmation of REACH compliance or a specific declaration.
For items where the customer specifies the material, the responsibility for compliance often rests with the customer. They have chosen the material and are aware of its composition. Your responsibility is to provide accurate information about what you have delivered.
The Bottom Line
REACH compliance for precision metal parts is not a matter of registering your finished components. The article exemption takes care of that. The practical work involves tracking candidate list substances, communicating with your customers and maintaining accurate records. It is about knowing the composition of what you make and being ready to share that knowledge.
