REACH SVHC Requirements for Tool Exporters

Why REACH SVHC Applies to Carbide Cutting Tools

If you ship carbide end mills, drills, or taps into the EU, your customer's compliance team will eventually ask about REACH. The regulation places obligations on what you put on the market, and carbide tools contain cobalt and nickel — both under regulatory scrutiny. For machine shop buyers and process engineers, understanding the SVHC list and the 0.1% threshold prevents customs delays and supplier disqualification.

The SVHC List and the 0.1% Threshold

REACH's Candidate List of Substances of Very High Concern (SVHC) is updated twice a year. The threshold is 0.1% by weight per article. A carbide insert is an article; each tool is assessed individually, not the shipment as a whole. If any SVHC exceeds 0.1% w/w in any component, information duties are triggered even if the substance poses no exposure risk in normal use.

• Cobalt metal and cobalt compounds: relevant to carbide substrates and some PVD targets
• Nickel: relevant to binder systems and certain coatings or shank materials
• Process chemicals used in coating or brazing that may remain as residuals

Threshold calculations should be documented per part number, with material declarations from your carbide rod and coating suppliers kept on file.

Information Transfer and the SCIP Database

Under the Waste Framework Directive, suppliers of articles containing SVHC above 0.1% must submit information to ECHA's SCIP database before placing the article on the EU market. Your EU importer or only representative typically files, but they need data from you: part identity, SVHC name, concentration range, and safe-use information. Beyond SCIP, REACH Article 33 requires you to pass sufficient information down the supply chain so professional customers can use the article safely. A compliant response is not a generic statement — it should reference the specific SVHC, its location in the tool, and handling guidance for grinding, regrinding, and disposal.

Documents to Provide Your Customers

Prepare a documentation pack that a buyer can file directly:

• REACH/SVHC declaration per part number, stating whether any Candidate List substance exceeds 0.1% w/w
• Safety data sheets where mixtures or processing fluids are supplied
• Material and coating declarations from upstream suppliers, traceable to batch
• SCIP submission confirmation or the data package enabling your importer to file
• Statements covering RoHS and applicable CE conformity where relevant, kept separate from REACH claims

For cobalt-bearing carbide, also confirm the classification and safe-use advice for dust generated during regrinding. Shops that regrind tools in-house need this to protect workers and maintain their own compliance records.

A Practical Compliance Path for Tool Suppliers

Exactalloy (铸屹精密) supports export documentation with batch-level traceability covering material, coating, and inspection records, and can supply REACH-oriented declarations alongside ISO 9001-controlled production. A sensible next step: request a part-number-level SVHC declaration and SCIP data package from your tool supplier, then verify that the 0.1% assessment is made per article rather than per shipment — and ask whether cobalt and nickel content is documented for every grade you buy.