A guide into stress-free product compliance

Smart chemical testing plan for metals & alloys

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

How to make a smart, reasonable cost effective testing plan for chemical safety for non-food consumer products? Or how to avoid unnecessary costs on chemical analysis?

Example :   

Metallic components (alloys) made from steel, aluminium, brass, etc. (for example bolts, screws, metallic machine and apparatus housings). These can be a part of i.a. kitchenware, tools, devices, etc.

The first step would be to make an inventory. For making an inventory of the chemical requirements you need to investigate which chemical legislative requirements are applicable for your product and the components of your product.

On of these chemical legislative requirements is (EC) Regulation 1907/2006 on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). REACH is always applicable to every product. Next to REACH you may have to deal with other chemical legislation, depending on the intended use of the product. Examples for which specific chemical legislation is applicable are toys, medical devices, electronic and electric apparatus and products that come in contact with food.

How to

As economic operator (for example: manufacturer, distributor, importer, etc), you must exactly know what your product is made of. In order to know this, for each material you must know how it is manufactured and is processed. So, how do you know which chemicals are incorporated in your product when you don’t manufacture the product yourselves? The most importent starting point is the Bill of Materials (BOM). In the BOM the materials and components used are listed, which should include detailed physical and chemical specifications for each material or materials present in a component.

In your buying process you should require the delivery of a detailed BOM. It is always better to require the BOM before you agree to buy the product, rather than when the product is already in customs. A good relation with your supplier(s) is thus essential. 

If you know which type of alloys are processed in your product, you can ask your supplier for composition certificates that include maximum impurities present in each alloy. In the metal industry they also call this a mill test report (MTR).  Other common terms for this certificate can also be ‘certified mill test report’, ‘certified material test report’, ‘mill test certificate (MTC)’, 'inspection certificate', and ‘certificate of test’. 

The mill test report is the evidence you must require. It certifies a material's chemical and physical properties and states that a product made of metal (steel, aluminum, brass or other alloys) complies with international standards such as ANSI, ASME, etc.
Mill here refers to an industry which manufactures and processes raw materials.

For the alloy substrate for which you can obtain composition certificates, there is no need for chemical analysis on hazardous substances for which restriction apply such as  SVHC’s or POPs.

If you cannot obtain a mill test report or similar evidence you may consider to send your product to a laboratory for chemical analysis, however, you should not prefer this. If we were responsible for quality and compliance with your company, we should consider it as a dealbreaker if your supplier cannot submit alloy composition certificates.

Surface of metallic objects are usually treated in order to making them more attractive and to protecting them against scratching, peeling, corrosion etc..

The coating of the metallic parts may contain SVHCs, however, the risk that a certain SVHC content in the components of your article will exceed the threshold of 0,1% SVHC in weight is nil.

Nonetheless we recommend asking for technical (chemical) details with your supplier respectively your manufacturer on applied coatings.

Below some examples of surface treatments of metals and alloys.

The following surface treatments use SVHCs in the production process:

  • Chromic anodising - in anodising electrolyte
  • Dichromate sealed sulphuric/hard anodising - in the sealing solution
  • Alocrom 1200 and Alocrom 1000 - in the conversion coating solution
  • Stainless steel passivation - in some passivation and post-passivation solutions, SVHC-free alternatives also available
  • Zinc plating - with hexavalent/colour passivate - SVHC-free alternatives also available
  • Some paint systems, chromate containing

For the following treatments, it is unlikely that SVHCs are being used in the production process:

  • Sulphuric/hard anodising - except when dichromate sealed
  • Surtec 650V
  • Iridite NCP
  • Zinc-nickel plating
  • Zinc plating - except with hexavalent/colour passivate
  • Some paint systems, free from chromates
  • Titanium anodising
  • Stainless steel passivation, nitric only
  • Stainless steel pickling
  • Dry film lubricants

The following treatments contain or may contain SVHCs in the final coating:

  • Chromic anodising (possibly above threshold)
  • Dichromate sealed sulphuric/hard anodising (likely above threshold)
  • Alocrom 1200 and Alocrom 1000 (likely above threshold)
  • Chromate-based paint systems (likely above threshold)
  • Zinc plating with hexavalent/colour passivate (possibly above threshold)

Although your metallic product or product component may need to undergo chemical testing, i.e. if it is intended to have food contact or if it has prolonged skin contact or for other product category related reasons, you will safe costs on chemical analysis by obtaining technical information and evidence with you supplier.


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