If you export steel to Europe, sooner or later a buyer will ask for REACH and RoHS compliance documents. For many first-time exporters the request arrives at the worst moment: after the price is agreed and just before the shipment is booked. This guide explains what the two regulations actually cover for steel, which documents buyers expect, and how to get them without delaying your order.
REACH and RoHS are two different “environmental security checks”. REACH is the EU chemicals regulation: for steel, it mainly asks whether the product contains any Substance of Very High Concern (SVHC) above 0.1% by weight. RoHS restricts 10 hazardous substances in electrical and electronic equipment: it applies to steel when the steel ends up in an appliance, computer, phone or other electrical product. In practice, a buyer usually wants a REACH declaration of conformity plus a RoHS test report from a third-party lab such as SGS or Intertek. Large Chinese steel mills issue both every year.
REACH vs RoHS at a glance
| REACH | RoHS | |
|---|---|---|
| Full name | Registration, Evaluation, Authorisation and Restriction of Chemicals | Restriction of Hazardous Substances in electrical and electronic equipment |
| Legal basis | Regulation (EC) No 1907/2006: applies directly in all EU member states | Directive 2011/65/EU (RoHS 2), amended by Directive (EU) 2015/863 (RoHS 3) |
| What it covers | Chemical substances on their own, in mixtures and in articles: practically every product placed on the EU market | Electrical and electronic equipment (EEE) and its parts |
| Key list | SVHC Candidate List: 253 entries (latest update February 2026) | 10 restricted substances |
| Key threshold | 0.1% w/w per article for SVHC communication | 0.1% w/w (cadmium 0.01%) in each homogeneous material |
| When a steel buyer asks for it | Almost every EU shipment, including automotive steel | When the steel is used in appliances, IT equipment, electronics, lighting and similar products |
| Typical document | REACH declaration of conformity / SVHC statement | RoHS test report (SGS, Intertek, etc.) + RoHS declaration |
What is REACH, and what does it mean for steel?
REACH is built on the principle of “no data, no market”: a chemical substance cannot be placed on the EU market unless its safety has been demonstrated and it has been registered with the European Chemicals Agency (ECHA).
For steel, REACH is usually not about the main alloying elements such as nickel, chromium or molybdenum in their metallic form. It is about specific compounds or forms of substances that could enter the product during steelmaking or processing, or as impurities: for example in coatings, passivation layers, oils or surface treatments. The question the buyer is asking is simple: does this steel contain any SVHC above the legal threshold?
The SVHC Candidate List in 2026
On 4 February 2026, ECHA added two substances (n-hexane and bisphenol AF and its salts) to the Candidate List, bringing it to 253 entries. Some entries cover whole groups of substances, so the number of individual chemicals is higher. ECHA usually updates the list twice a year, and legal obligations start as soon as a substance is added. That is why buyers often ask for a declaration that names the current list version, e.g. “SVHC-253”. Always check the latest version on the ECHA Candidate List.
REACH obligations that apply to steel products
Flat steel products such as sheet, strip and coil are generally treated as articles under REACH. For articles, the obligations that matter in practice are:
- Article 33: supply-chain communication. If an article contains an SVHC above 0.1% w/w, the supplier must give customers enough information to use it safely, at least the name of the substance. Consumers can request the same information and must receive it within 45 days.
- Article 7(2): ECHA notification. Producers and importers must notify ECHA if an SVHC is above 0.1% w/w and the total quantity exceeds 1 tonne per year, within six months of the substance being listed.
- SCIP database. Under the EU Waste Framework Directive, articles containing a Candidate List SVHC above 0.1% w/w must be notified to ECHA’s SCIP database.
- Annex XVII restrictions. Some substances are restricted outright in certain products, independent of the Candidate List.
For a properly produced carbon steel or coated automotive sheet, the answer is normally “no SVHC above 0.1%”. But buyers still ask for the statement in writing, because they carry the legal obligation when they place the product on the EU market.
What is RoHS, and when does it apply to steel?
RoHS restricts hazardous substances in electrical and electronic equipment. Steel is an industrial raw material, not an electronic product, so RoHS does not apply to steel as such. It becomes relevant when your steel is used to make housings or parts of home appliances, computers, phones, lighting, power equipment or other EEE. In that case the buyer will ask you to prove that the steel does not contain RoHS-restricted substances above the limits. For steel, the main concerns are lead, cadmium and hexavalent chromium.
The 10 RoHS restricted substances and limits
| # | Substance | Maximum concentration (by weight in homogeneous material) | Relevance to steel |
|---|---|---|---|
| 1 | Lead (Pb) | 0.1% | Free-machining steels, some galvanizing baths |
| 2 | Mercury (Hg) | 0.1% | Rarely relevant |
| 3 | Cadmium (Cd) | 0.01% | Old plating systems; impurity control |
| 4 | Hexavalent chromium (Cr VI) | 0.1% | Chromate passivation on galvanized or electro-galvanized steel |
| 5 | Polybrominated biphenyls (PBB) | 0.1% | Flame retardants: not normally in steel |
| 6 | Polybrominated diphenyl ethers (PBDE) | 0.1% | Flame retardants: not normally in steel |
| 7 | Bis(2-ethylhexyl) phthalate (DEHP) | 0.1% | Plasticizers: films, coatings, packaging in contact with the product |
| 8 | Butyl benzyl phthalate (BBP) | 0.1% | Same as above |
| 9 | Dibutyl phthalate (DBP) | 0.1% | Same as above |
| 10 | Diisobutyl phthalate (DIBP) | 0.1% | Same as above |
The four phthalates (7–10) were added by Directive (EU) 2015/863 and have applied in the EU since 22 July 2019. A full list is also available in the RoHS Guide substance list.
Lead in steel: the RoHS exemption to watch
Lead is sometimes added to free-machining steel to improve machinability. RoHS allows this under Annex III exemption 6(a). In November 2025 the EU revised it: 6(a)-I allows up to 0.35% lead in steel for machining purposes, and 6(a)-II allows up to 0.2% lead in batch hot-dip galvanized steel components. Both are set to expire on 30 June 2027, and the old combined 6(a) entry expires on 11 December 2026. If your product relies on leaded steel for an EEE application, start planning the switch now.
China RoHS: now aligned with the EU
China has also tightened its rules. From 1 January 2026, Amendment No. 1 to GB/T 26572-2011 added the same four phthalates, so China RoHS now restricts the same 10 substances as EU RoHS. The new mandatory national standard GB 26572-2025 takes effect on 1 August 2027. For steel suppliers in China, this means one RoHS test scope can now support both EU and Chinese customers.
Automotive steel: ELV and IMDS
For vehicles, the closest equivalent to RoHS is the EU End-of-Life Vehicles (ELV) Directive 2000/53/EC. It bans lead, mercury, cadmium and hexavalent chromium in vehicle materials and components, with specific exemptions listed in Annex II (for example, lead as an alloying element in steel for machining purposes up to 0.35%). Automotive customers usually ask suppliers to report material composition through the IMDS (International Material Data System) in addition to REACH declarations. Chromium-free or trivalent passivation on galvanized automotive steel is now the norm.
What happens if steel is not REACH or RoHS compliant?
- Shipments held at the border. EU customs and market surveillance authorities can detain goods that arrive without the required compliance information. If restricted substances are found above the limits, the goods may be destroyed or returned at the importer’s cost, adding freight and product losses.
- Loss of market access. Non-compliant products can be withdrawn or recalled, and serious or repeated violations can effectively close the EU market to the supplier.
- Fines and criminal liability. Penalties are set by each EU member state. Depending on the severity, companies can face heavy fines, and in some countries the responsible persons can face criminal charges.
- Lost customers. Large end users such as carmakers and appliance makers will not buy steel that cannot be supported with REACH and RoHS documents. For them it is a supply-chain risk, not a paperwork preference.
Which REACH and RoHS documents do steel buyers ask for?
| Document | Issued by | What it proves | Notes |
|---|---|---|---|
| REACH declaration of conformity | Steel mill or trader (signed) | The product complies with REACH: registration completed or exemption applies, and no SVHC above 0.1% w/w | Should name the SVHC list version (e.g. SVHC-253) and the product scope |
| SVHC test report | Third-party laboratory | Measured screening of SVHC content | Mandatory information only if an SVHC exceeds 0.1%; buyers often ask for it anyway as evidence for their own due diligence |
| RoHS test report | Third-party laboratory, e.g. SGS or Intertek | Pb, Cd, Hg, Cr(VI), PBB, PBDE and the four phthalates are below the RoHS limits | The most commonly requested document; check the test date and the material described |
| RoHS declaration | Steel mill or trader | The supplied material meets RoHS limits | Usually supplied together with the test report |
| Mill test certificate (MTC) | Steel mill | Chemical composition and mechanical properties per heat/batch | EN 10204 3.1 / 3.2; links the shipment to the compliance documents |
How to get REACH and RoHS documents for steel
Option 1: from the steel mill (lowest cost, most formal)
Large Chinese steel mills have already completed their REACH and RoHS commitments in both Chinese and English, and renew their third-party test reports regularly; Baosteel, for example, typically updates its reports around May each year. A trader only needs to add the shipment-related information (product, grade, heat or batch numbers) before passing them to the buyer.
Option 2: test it yourself (full control)
If the mill cannot provide documents for a special product, or the buyer insists on a specific laboratory such as SGS, you will need your own test.
- Contact a testing laboratory (e.g. SGS, Intertek).
- Apply for the RoHS and/or REACH SVHC test scope you need.
- Send steel samples.
- The laboratory analyses the samples.
- You receive the report, in English and Chinese if requested.
Time and cost: usually 2–4 weeks; the cost depends on the test scope. Because steel is a homogeneous material, one report can often be used for several shipments, as long as the grade, process and coating are the same and the heat/batch documents match. Confirm with your buyer that they accept this.
Option 3: ask your supplier (quick and practical)
If you buy from another trader, ask whether they can provide the documents. Experienced export traders often include compliance documents as part of their service.
Before forwarding any document, check three things: the product type and grade, the country and mill of origin, and the validity date. A RoHS report for cold-rolled steel from one mill does not cover galvanized steel from another mill.
A practical tip on coil labels and certificates
Some mills that apply strict environmental controls add REACH or RoHS marks to coil labels or mill test certificates. As a trader, it is better not to promise or highlight these marks to overseas buyers. They are a mill-specific service: if you later supply the same grade from another mill that does not print them, the buyer may wrongly think the material has changed or is non-compliant. Base your commitment on the declaration and test report, not on the label.
FAQ
Does steel need REACH registration?
Steel products such as sheet and coil are normally articles, so the importer does not register them. The substances used to make the steel are registered by the producers. What buyers need from you is confirmation that no SVHC on the current Candidate List is present above 0.1% w/w.
Is a RoHS report needed for automotive steel?
Vehicles are covered by the ELV Directive rather than RoHS. But steel for automotive electronics, motors or charging equipment may fall under RoHS, and many automotive buyers ask for a RoHS report anyway as part of their material compliance file.
How long is a RoHS test report valid?
RoHS reports have no legal expiry date, but most buyers accept reports no older than about 12 months, and require a new test when the regulation, the material or the process changes.
MOOPEC is a Shanghai-based metal supply and deep-processing specialist supplying automotive steel, electrical steel and aluminum to global OEM and Tier-1 buyers. Every shipment can be supported with mill test certificates and current REACH and RoHS documents for the grade and mill supplied. Exporting to the EU and need a compliance file that matches your order? Tell us the grade, origin and end use, and we will confirm which documents we can supply before you place the order. You can also browse our cold-rolled and galvanized automotive steel ranges.
