RoHS, REACH and Conflict Minerals: Export Compliance for Roll Forming

I'm Iris Xu, a Sales Manager in ZTRFM. A buyer in Poland once told me that roll-formed steel is just metal and therefore sits outside EU chemical law. That belief has caused more delayed shipments than any price disagreement I have seen. Steel sections are articles, and articles carry obligations the moment they are coated, plated, or built into electrical equipment.

Why a bare profile is not blank on the regulator's desk

Roll forming itself adds no chemistry. We shape cold-rolled strip through successive rolls at room temperature. The compliance question starts with what sits on the surface and where the part ends up. A plain uncoated structural channel has little to declare. The same channel, sent through a zinc bath or painted with a primer, now carries substances that three separate EU regimes watch.

RoHS 2011/65/EU: it is about the equipment, not the steel alone

RoHS restricts ten hazardous substances in electrical and electronic equipment, known as EEE. The thresholds apply per homogeneous material: lead and hexavalant chromium at 0.1 percent by weight, cadmium at 0.01 percent, plus mercury, PBB, PBDE and four phthalates named DEHP, BBP, DBP and DIBP. The directive has applied since 2 January 2013 and is the legal basis for the CE mark on covered products.

For a roll-formed profile, RoHS bites in two places. First, if the section is a component of EEE, such as a rail inside a vending machine or a bracket in a control cabinet, the whole assembly must conform. Second, surface treatments matter. Hexavalant chromium in a conversion coating, or lead in certain legacy primers, would breach the limit even on a mechanical part. We avoid hex-chrome passivation and document the coating chemistry so a buyer can file a compliant technical file.

REACH (EC) 1907/2006: the registration that follows the substance

REACH covers registration, evaluation, authorisation and restriction of chemicals. Its SVHC candidate list is the part buyers ask about. The list passed 250 entries and reached 253 in ECHA's February 2026 update. If an article contains an SVHC above 0.1 percent by weight and the producer or importer handles more than one tonne per year, ECHA must be notified, and the substance must be communicated down the supply chain under Article 33.

Coatings are the link to roll forming. Zinc and aluminium baths are generally benign, but some additives, pigments and post-paint systems contain listed substances. We keep the declared formulation of every coating we run and issue a REACH communication statement naming the article, the substance and the concentration band. That document is what a German distributor needs to answer a customer within 45 days.

How to read a supplier's declaration

A declaration is only as good as the data behind it. We ask the coating supplier for the formulation, then we state only what we can name. A buyer should do the reverse: treat a one-line compliant letter with suspicion and ask for the substance list and the concentration band. The useful declarations name the exact coating, the CAS where relevant, and the measured or calculated percentage. A blank certificate that only repeats the law proves nothing and will not survive a market-surveillance check.

Where the rules overlap on one part

A single painted bracket can touch all three regimes at once. It is an article under REACH, it may sit inside EEE under RoHS, and if it is plated it pulls in 3TG questions from the OEM. That is why we build one material file per part instead of three separate letters. The coil cert, the coating data, and the declaration sit together, so the buyer answering a German distributor and a Japanese car maker uses the same source. Fewer files means fewer contradictions.

The cost of getting it wrong

A non-compliant part does not fail at the factory gate. It fails at the border, or worse, on a retailer's shelf after a random test. The EU runs coordinated checks, and missing or false paperwork alone can stop a shipment. The fix is cheap and early: one material file per part, written before the first coil is slit. We treat that file as part of the product, not a separate chore.

Conflict minerals: 3TG and the supply-chain letter

The four conflict minerals are tin, tantalum, tungsten and gold, known as 3TG. In the United States, Section 1502 of the Dodd-Frank Act directs the SEC to require listed companies to report 3TG that is necessary to a product's function or production. The EU has its own Conflict Minerals Regulation, number 2017/821, for importers of the metals and their derivatives.

For most roll-formed sections, 3TG is not present in the steel. The real exposure is plating and electronics: gold flash on contacts, tin in solders, tungsten carbide in tooling. We do not sell tungsten carbide parts, but automotive OEMs still push a Conflict Minerals Reporting Template, called CMRT, down to every supplier, because their calculators and connectors contain 3TG. A mill certificate that names the melt and the coating, plus a short declaration, lets the buyer answer the questionnaire honestly.

What actually clears the shipment

No single certificate covers all three rules. What works is a small paper set:

• An EN 10204 type 3.1 material certificate from the coil mill, naming grade and coating.
• A RoHS declaration stating the part is outside EEE scope, or conforming if it is inside.
• A REACH Article 33 statement listing any SVHC above 0.1 percent, or stating none.
• A CMRT or short conflict-minerals letter where the buyer's OEM requires it.

A note on automotive buyers

Car makers run the strictest chain. They ask for IATF 16949:2016 from the plant and a REACH plus conflict-minerals package from the part. The good news is that the same mill certificate serves all three requests, so one document set travels from the steel mill to the customs file. Build it once and the next order is a copy, not a scramble.

The practical takeaway

If you sell profiles into the EU, ask your supplier for the coating formulation before you quote, not after customs holds the container. A two-hour document review at the engineering stage prevents a six-week stop at the border. At ZTRFM we keep these declarations on file for the lines we run, so an export inquiry can leave with the compliance folder attached.

Compliance is not a department in another building. It is the coating choice we make on the line and the certificate we hand you with the pallet. If your next project needs EU-ready sections, start the paper trail with the first sample.