Define article or mixture
A stainless product whose shape, surface or design determines function may be an article, while cleaners, pickles and coatings can be substances or mixtures.
Technical guide
Stainless Steel REACH Compliance
Stainless steel REACH compliance is not proven by a generic statement that metal is exempt. Duties depend on the supplied object, legal role, substances present, Candidate List status, concentration, tonnage, intended release and market date.
Key threshold0.1% w/w for Candidate List articles
Separate testOne tonne per year for Article 7 notification
Living referenceCandidate List changes over time
Decision summary
Determine the legal object and supply-chain role first
Stainless sheet, a fabricated component, a chemical treatment product and scrap are not assessed in the same way. The importer, producer and distributor may also have different duties.
Identify the EU legal role
Record who manufactures, imports or supplies the product and who holds the underlying substance information.
Screen the current Candidate List
Check every supplied article against the list effective on the declaration date and retain the composition basis.
Apply Article 33 communication
If a Candidate List substance exceeds 0.1% w/w in an article, provide sufficient safe-use information and at least the substance name.
Assess Article 7 notification separately
Producer or importer notification can depend on the 0.1% threshold, total quantity above one tonne per year and available exemptions.
Check restrictions and SCIP
Candidate List communication, REACH restrictions, authorization and SCIP reporting are separate questions and must not be collapsed into one certificate.
Reference table
REACH evidence and decision matrix
Use this matrix to request evidence that matches the supplied object and the company role rather than a one-line unrestricted claim.
| Decision area | Question to answer | Evidence to retain | Update trigger |
|---|---|---|---|
| Product status | Is the supplied item an article, substance, mixture or waste at this stage? | Product description, drawings, use and legal assessment | Change in form, processing or supply route |
| Legal role | Who is EU manufacturer, importer, only representative or distributor? | Entity and tonnage map, contracts and supplier chain | New supplier, importer or legal entity |
| Candidate List | Does any article contain a listed substance above 0.1% w/w? | Current list date, composition evidence and calculation basis | Each Candidate List update or composition change |
| Article 33 | What safe-use information must be passed to recipients or consumers? | Controlled declaration, substance name and handling information | New SVHC, use or recipient information |
| Article 7(2) | Are threshold, annual tonnage and notification conditions met? | Tonnage calculation, exposure or registration exemption rationale | Annual volume or use change |
| Restrictions and authorization | Does Annex XVII or Annex XIV affect manufacture, placing on market or use? | Applicable entry review, use conditions and authorization reference | Regulatory amendment or new use |
| SCIP | Is an EU Waste Framework Directive submission required for an article? | Article hierarchy, identifiers, SVHC data and submission record | Product or Candidate List change |
The 0.1% threshold applies to each article supplied. Complex objects require analysis at the relevant component-article level rather than dilution across the whole assembly.
Working method
Maintain a dated and reviewable compliance file
A reliable declaration states what was assessed, which list and law version were used, and the limits of the supplier information.
Map products and roles
List article structure, suppliers, EU entities, tonnages, uses and any intentional substance release.
Collect composition evidence
Obtain controlled material declarations, specifications and substance information linked to the delivered grade and component.
Run each legal decision
Assess Candidate List communication, notification, restrictions, authorization and SCIP as separate obligations.
Issue and maintain declarations
State scope, part numbers, list date, threshold conclusion, exceptions, signer and review trigger.
Limits and escalation
Reject vague or permanent compliance claims
A grade name is not a full declaration
Alloy designation alone may not address coatings, oils, fasteners, weld consumables or other components in the supplied article.
Below threshold is time-specific
Candidate List additions and supplier composition changes can alter the conclusion after a declaration is issued.
Article 33 is not a ban
Presence above 0.1% triggers communication duties; authorization, restriction and product-law consequences require separate review.
REACH is not RoHS
The regimes have different scopes, substance lists, thresholds and evidence. One declaration should not be substituted for the other.
Interactive planning aid
Identify the first REACH compliance action
Select the supplied object and Candidate List status. The result highlights the first assessment and record to prepare.
Frequently asked questions
Stainless steel REACH compliance FAQ
No blanket statement covers every duty. The analysis depends on whether the supplied object is an article, substance or mixture, the company role, substances present, uses and applicable thresholds.
For Candidate List substances in articles, Article 33 communication duties apply above 0.1% weight by weight. Other duties use additional tests and conditions.
No. An MTC supports material identity and reported properties but normally does not complete current Candidate List, component, restriction, authorization or SCIP analysis.
Review it when the Candidate List or law changes, a supplier or composition changes, a product is redesigned, a new use is introduced or the legal role and tonnage change.
Method, sources and review
Traceable sources and review status
Official current list of substances of very high concern for authorization.
Official guidance on communication for Candidate List substances above 0.1% w/w in articles.
Official Article 7(2) threshold, tonnage and exemption overview.
Official information for the database of substances of concern in articles and complex objects.
This is a compliance workflow, not legal advice or a product declaration. Verify the current EU text, Candidate List, company role, product composition and competent authority expectations.
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REACH compliance context
Set the material, use and documentation scope before making a REACH statement.
Compliance review needs the supplied material identity, intended use, applicable substances and documentation route. A general material claim does not replace supplier-specific evidence.
Material identityDefine the grade, form and supplier route under review.
Use contextRecord the intended use and any customer-specific restrictions.
Evidence routeRequest declarations and test evidence appropriate to the supply.
Visual reference
Show the material route and compliance evidence together.
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Supply identification
Reserved for traceable material and product-form context.
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Compliance evidence
Reserved for declarations and controlled documentation.
Engineering and sourcing support
Define the evidence scope for a REACH declaration
Send product and component list, grades, coatings, oils, suppliers, EU legal role, annual tonnage, intended uses, Candidate List evidence, destination and requested declaration date.