QuotedPartAnswers · Updated 2026-10-30
Customers want full material disclosure, RoHS/REACH or PFAS declarations: what does a small shop do?
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Sign only what you know first-hand, pass through what the mill and the finisher told you in writing, and write "not known" for the rest. A shop that cuts a bar of 6061 knows the alloy (the mill cert says so), the cutting fluid it ran, and what it did to the part. It does not know the chemistry of a plating bath or an O-ring, and a signature on that is a promise you cannot back. If the form takes real time, bill it: 45 minutes at $75 an hour is $56.25 a part number, an example worked out below.
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Three different requests that get lumped together
A RoHS certificate, a REACH statement and a full material disclosure (FMD) are not the same document, and answering the wrong one is how shops end up signing things that are not true.
RoHS is a restriction on ten substances in electrical and electronic equipment. The European Commission lists lead, cadmium, mercury, hexavalent chromium, the flame retardants PBB and PBDE, and four phthalates (DEHP, BBP, DBP, DIBP), and says the directive applies to products with an electrical or electronic component. A plain machined bracket is a part of someone else's equipment: the equipment maker carries the RoHS obligation and asks you for supplier data to support it.
REACH asks whether the part contains a Candidate List substance (a Substance of Very High Concern) above 0.1% by weight. The list is maintained by ECHA and changes twice a year, so a statement you sign today has a date on it. A full material disclosure is the broadest: the buyer wants every material and substance in the part, often on an IPC-1752 style spreadsheet or the buyer's own template.
What a job shop can sign and what belongs to someone else
The table sorts the usual line items by who actually knows the answer. The shop's signature belongs on the first column only; for the rest, attach the supplier's own paper.
| Item on the form | Who knows | What the shop can do |
|---|---|---|
| Alloy and composition of the bar or plate | The mill, on its test cert | Attach the mill cert for the heat or lot; do not retype the chemistry yourself |
| RoHS and REACH status of the raw material | The mill or the distributor | Ask for their declaration (letter below) and forward it with the date it was issued |
| Coolants, oils, lubricants, tapping fluid used on the part | The shop, from the safety data sheets | State what you use and attach the SDS; say whether you looked for fluorinated ingredients |
| Plating, anodize, chem film, paint, passivation | The finisher | Forward the finisher's declaration; never sign for a bath you do not run |
| PTFE, FKM or other fluoropolymer stock, seals and coatings | The material supplier | These are usually counted as PFAS under the broad OECD definition; ask the customer which definition their form uses |
| What you did not add (no paint, no plating, no purchased hardware) | The shop | Say so in one sentence; this is the easiest line to sign |
PFAS: where it can turn up in a machining job
In a typical shop the honest list is short. PTFE and other fluoropolymer stock is PFAS under the broad definition the OECD uses. Fluoroelastomer O-rings and seals, PTFE-coated fasteners and thread tape count too, and so do some specialty greases. Finishers are the other place to ask: chemical conversion coatings and chrome plating lines have a history of hexavalent chromium and fluorinated mist suppressants, and only the finisher can tell you what its bath contains today.
The rules the buyer is reacting to are still moving. EPA's TSCA section 8(a)(7) reporting rule for PFAS covers importers of PFAS-containing articles as it stands, and EPA moved the start of the reporting period in April 2026 while a narrower revision is pending (EPA page, last updated April 16, 2026, checked October 30, 2026). That rule is aimed at importers and manufacturers, not at a shop turning a customer's part from bar, but the buyer's own compliance team is the one asking you.
A letter that gets answers from suppliers
Send this to the mill or distributor and each finisher once, keep the replies in a folder by supplier, and reuse them for every customer who asks.
"We supply machined parts to customers who require material declarations. For the material and process listed below, please send within 10 business days: (1) your RoHS and REACH declaration for this product, with date; (2) whether it contains any substance on the current ECHA Candidate List above 0.1% by weight; (3) whether any PFAS, as defined by [OECD 2021 / the customer's definition], is present in the material, the coating or the process chemistry; (4) the date of your latest review. If you cannot confirm any item, please say so in writing. Part: [description]. Lot or heat: [number]."
If a supplier refuses or does not answer, write that on the form: "Supplier declaration requested [date], not received." That is a true statement, and the buyer can decide what to do with it.
Charging for it: a 45-minute example
Time a typical first request honestly: 45 minutes to read the form, pull the supplier declarations, attach the mill cert and send it back. At the starting inspection rate of $75 an hour that is $56.25 per part number. Repeat requests for the same part number take 10 to 15 minutes, since the supplier letters are already on file. These minutes are an example for the worked arithmetic, not an industry average.
Put it on the quote as its own line ("Material and compliance documentation, per part number") so the buyer sees it before the PO. A buyer with a hundred part numbers will push back on a per-part fee, which is a good moment to offer a flat annual compliance fee and a standing declaration per supplier instead.
Sources and limits
Claims are dated where they can change. Product calculations are examples from the stated inputs, not a promise about a customer's quote. Competitor wording is attributed to the source shown.
- RoHS restricts lead, cadmium, mercury, hexavalent chromium, PBB, PBDE and four phthalates, and covers products with an electrical or electronic component. — source (checked 2026-10-30)
- EPA's TSCA 8(a)(7) PFAS reporting start was moved in April 2026 and the scope revision was still pending when the page was last updated on April 16, 2026. — source (checked 2026-10-30)
- Paperwork time and the $75 hourly inspection rate are example inputs, not averages.
Questions
Can I just say we are RoHS compliant?
Only if you can back it. A machined metal part from a mill-certified bar is usually fine on the metal itself, but the plating or conversion coating and any purchased hardware are other companies' products. Say what the declaration rests on: "based on supplier declarations dated ...".
What if the customer's form has fields I cannot fill in?
Write "not known to us, supplier declaration attached" or "requested, not received" in each one. Never leave a field blank and never guess; a blank gets filled in by the buyer's assumptions.
Is this legal advice?
No. The rules above are summaries of public sources checked on the date shown. If a contract makes you liable for a declaration, have the wording checked by whoever advises your shop on contracts.
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