1) Scope — what’s “in scope” for empty hardware

RoHS/REACH scope covers materials, components, and finishes used in empty devices: stainless tubes and mouthpieces, aluminum shells, plated brass sub-components, polymer housings (PCTG, PC/ABS, PEEK), elastomers, adhesives, inks and paints—especially coatings/platings that could introduce restricted substances.

Operationally, align this article with your receiving SOP in Incoming QC for Empty Vape Hardware (AQL & Airflow Tests).

2) RoHS restricted substances & numeric limits

Verify declarations and reports against Annex II limits under RoHS (2011/65/EU as amended by (EU) 2015/863). Thresholds per homogeneous material are:

• Cadmium (Cd): ≤ 0.01% (100 ppm)
• Lead (Pb), Mercury (Hg), Hexavalent Chromium (Cr(VI)), PBB, PBDE: ≤ 0.1% (1000 ppm)
• Phthalates: DEHP, BBP, DBP, DIBP — each ≤ 0.1% (1000 ppm)

Use part-number mapping and finish-specific declarations; for plated parts that may be in direct and prolonged skin contact, consider EN 1811 nickel-release evaluation (limit 0.5 μg/cm²/week; ≤0.88 μg/cm²/week deemed compliant per the latest interpretation).^[1][2][3][4]

3) Supplier Documentation Pack (what to request)

• DoC/CoC (RoHS & REACH) referencing part numbers, revisions, finishes, and third-party report IDs.
• Material grades (e.g., 316L/304 stainless; PCTG/PC/ABS/PEEK resins) and finish declarations (Ni/Cr plating, PVD, anodizing, inks/paints).
• Third-party reports tied to lots/finishes: metals, brominated flame retardants, phthalates, nickel release, solvent/VOC screening.
• Lot/date code mapping and a BOM view of which sub-parts each declaration covers.
• Change-control (ECO triggers): resin, pigment, plating bath or supplier changes → re-qualification & evidence refresh.

For broader purchasing controls, see our Safety & Compliance Buyer’s Checklist and Gage R&R & Uncertainty.

4) Accepted lab methods & accreditation

Methods. Request testing to the IEC 62321 series for RoHS substances—for example: XRF screening per 62321-3-1; digestion + ICP-OES/AAS per 62321-5/6 for metals/bromine; and IEC 62321-8 (GC-MS or Py/TD-GC-MS) for phthalates in polymers. Cite report numbers and sample IDs that map to your part numbers and finishes.^[5][6][7]

Accreditation. Use laboratories accredited to ISO/IEC 17025 by bodies that are signatories to the ILAC MRA; this supports international acceptance of results and regulator confidence. Keep the lab’s accreditation scope and validity with your files.^[8][9][10]

5) AQL + chemical sampling workflow

1. Routine AQL checks: appearance, dimensions, airflow (see our AQL & airflow SOP).
2. Risk triage: prioritize coatings/platings, dark pigments, adhesive/ink changes, supplier switches.
3. Periodic chemical tests: high-risk parts go to third-party labs on a defined cadence (or on change notices); keep raw data and chromatograms when available.
4. NCR/8D: for any failure, stop-ship, quarantine, root-cause, corrective actions, and supplier re-qualification.

6) Top 10 red flags

• Generic declarations without part numbers, finishes, or report IDs.
• Report dates not aligned to current finishes or supplier lots.
• Plated parts missing nickel-release assessment where applicable.
• Inks/paints with no solvent/VOC cure evidence or pigment disclosure.
• Polymer grades listed as “equivalent” with no datasheets or CAS families.
• No change-notification process for resin, pigment, plating bath, or supplier.
• Non-searchable “photo scans” of certificates; no lab contact or accreditation scope.
• Contradictory material claims (e.g., claims 316L but density/spark/hardness disagree).
• Carton lot codes don’t match certificates/test sample IDs.
• “One-and-done” testing with no plan to refresh after process changes or SVHC updates.

7) Quick FAQ

Do I need to quote the current SVHC count?

No—ECHA updates the Candidate List periodically. Link to the live list and ask suppliers to confirm “no SVHC >0.1% w/w in articles” (or list any present) at the time of declaration.^[11][12]

Should every shipment be tested?

Use risk-based periodic testing. Trigger re-tests on supplier/finish changes or adverse history, and maintain ISO/IEC 17025 + ILAC-MRA evidence for external acceptance.^[8][9]