RoHS and REACH Compliance for Magnetic Components: A Buyer's Checklist

Compliance Is Now a Purchasing Gate, Not a Paperwork Detail

For magnetic components, material compliance has moved from a trailing document request to an up-front gate: EU customers will not release a purchase order without a current declaration, and a single undeclared SVHC above 0.1 % by weight in an article can block a shipment at the border. The good news is that most of the risk sits in a small number of material families, and a buyer who asks five specific questions can close it before the first article is approved.

The Four Regimes That Apply to a Transformer or Inductor

Material compliance regimes and what each actually requires
Regime	Substances in scope	Deliverable	Refresh cycle
EU RoHS 2011/65/EU + (EU) 2015/863	10 restricted substances: Cd, Pb, Hg, Cr(VI), PBB, PBDE, and four phthalates	Declaration per part number with exemptions cited	On change, and at least annually
EU REACH 1907/2006	SVHC candidate list (updated twice a year) plus Annex XVII restrictions	Article declaration, SCIP notification where required	Every candidate-list update
Conflict minerals / 3TG	Tin, tantalum, tungsten, gold; increasingly cobalt	CMRT plus smelter list, EMRT for cobalt	Annual, or on supplier change
California Prop 65 and China RoHS	Prop 65 list; China RoHS substance disclosure	Warning assessment; EFUP table	Per market entry

Where the Risk Actually Lives in a Magnetic Component

Six material families carry nearly all of the exposure:

Solder and tinning. Lead-free is standard, but exemption 7(a) for high-melting-point solders and 7(c)-I for lead in glass or ceramic of electronic components still appear on some legacy parts; state which exemption, if any, your part uses.
Enamel and varnish. Older solvent varnishes and some polyurethane enamels have been reformulated for cresol and phenol content; ask for the current technical data sheet year.
Ferrite and powder cores. The ceramic body is generally clean, but the binder in pressed powder cores and the nickel or cobalt content in some alloys must be disclosed, especially high-flux and iron-powder grades.
Potting compound and adhesives. Epoxy systems can carry phthalate plasticizers or specific SVHCs; a cure change is a material change.
Lead wire and tubing. PVC tubing with certain plasticizers and some halogenated sleeving are the most frequent REACH issues in low-frequency transformer builds.
Packaging. Wood pallets require ISPM 15 heat treatment, and plastic bags fall under the EU packaging directive rather than RoHS, so they are often left out of declarations entirely.

The Five Questions That Close 90 % of the Exposure

Is the declaration per part number and does it name every material in the BOM, including varnish, tape, sleeving, and potting?
Which RoHS exemptions are claimed, by number?
What is the SVHC declaration date, and does it cover the most recent candidate-list update?
Is there a CMRT with smelter identification, and does the smelter list include only conformant smelters?
Who signs the declaration — the trading company or the manufacturing site? A declaration from a trader who does not control the BOM is worth little.

Document Control: The Part Buyers Get Wrong

Compliance fails at the change, not at the first shipment. A varnish substitution, a bobbin resin change for cost, or a switch of TIW supplier can each introduce a new substance while the part number stays the same. Ask for a written change-notification clause: no material change without written approval, and a refreshed declaration within 30 days of any approved change. Tie it to the PPAP or first-article process, so the declaration and the drawing revision move together.

What Good Looks Like

A compliant magnetic component file normally contains: a signed RoHS declaration with exemptions listed, a REACH SVHC statement dated within the last six months, a CMRT with smelters, material declarations for the varnish and potting system, and a change-notification clause in the quality agreement. Suppliers who manufacture in China and ship to the EU should also be able to issue a SCIP number for the article when an SVHC is present.

RoHS and REACH Compliance for Magnetic Components: A Buyer’s Checklist