EU applicability checklist
| Requirement | When it applies | What to request |
|---|---|---|
| CE marking | Regulated finished product/assembly, not normally a standalone structural part | Declaration of Conformity from responsible manufacturer |
| RoHS 2.0 | Electrical and electronic equipment | Material declaration or test report |
| REACH | Substances in articles and supply-chain communication | SVHC statement and compliance declaration |
| EN 10204 3.1 | Metal material traceability/customer specification | Mill test certificate with heat/lot data |
CE marking for metal parts is the most over-asked question we receive from EU buyers. Many teams assume that every metal component needs a mark. The official position is the opposite. Only products covered by the relevant EU rules may carry it, and affixing it to anything else is explicitly forbidden.
| The part ends up as | Does CE marking apply? | Who carries the duty |
| A plain bracket, panel or housing with no electrical function. | No, not in itself. | The rules reach the final machine, not the bracket. |
| A component with an electrical or electronic function. | It can be drawn in. | The rules for that product family, and often the final assembler. |
| A part of a machine that will be placed on the market. | The machine needs the mark. Its parts support that file. | The machine builder, as the responsible party. |
| A pressure-retaining part. | It can be, on its own category. | Depends on the category and on the risk. |
| A part inside an electrical and electronic product. | CE may not apply, while chemical rules still do. | Shared between the material supplier and the producer. |
Why a supplier cannot CE mark your bracket
In short, the mark is a declaration by the party who places the product on the market. That party takes legal responsibility for the whole product, not for one component inside it. So a bracket maker cannot sign that declaration on your behalf.
Therefore a supplier who offers a marked bracket is either describing something else or overstating. In practice the useful thing a supplier provides is evidence, not a mark.
The documents an EU buyer actually needs
First, ask for the material grade as it appears on the mill document, because that record anchors every downstream claim. Second, ask for the surface treatment and any coating specification, since those affect chemical compliance as much as the base metal does.
Next, ask for a declaration covering the restricted substances relevant to your product family. Then ask for a statement on substances of concern above the level set in the chemical rules, so your own file is complete.
In addition, keep the drawing revision with the shipment. A declaration that cannot be tied to a revision is hard to defend later. Everything in that list traces back to the records we already keep for CE marking for metal parts and routine inspection, so the two never disagree.
Where RoHS actually reaches a metal part
The restriction on hazardous substances applies to electrical and electronic equipment. In short, a stamped housing with no electronics usually sits outside it. However, the moment the part carries a connector, a switch or a sensor, the picture changes.
Consequently the honest answer to most EU buyers is that we will tell you exactly what is in the part, and you decide whether the regime reaches it. We cannot decide that for your end product.
REACH runs on a different logic
The chemical regime does not wait for an electrical function. It attaches to the article and to the substances inside it. If a substance of concern is present above the level set in the rules, information has to travel along the supply chain and reach the buyer.
Therefore a buyer can legitimately ask us for that information even for a plain part. The right request is specific. Name the substance list you work from, and we will answer against it rather than against a general promise.
What we put in the file, and what we will not
First, we supply the material record, the finish, the drawing revision and the inspection evidence. Furthermore, we keep the same descriptors across repeat orders, so your compliance file reads consistently from one shipment to the next.
However, we will not issue a CE declaration of conformity for your product, and we will not apply a mark. That belongs to the party placing the product on the market. That distinction is the one most often missed in a first enquiry. Our quality system is certified to ISO 9001:2015, and we will point you at the material and chemical evidence instead.
Frequently asked questions
These are the questions EU buyers ask most often about this split of duties.
Do all metal parts sold in the EU need CE marking?
No. The official position is that only products covered by the relevant rules may carry the mark, and it is forbidden to affix it to other products. A plain bracket normally sits outside those rules.
Can you send us a CE certificate for the parts?
We can send the material and inspection records that support your own file. We cannot issue a CE certificate for your product, because the declaration belongs to the party placing it on the market.
Does RoHS apply to stainless steel parts?
It applies to electrical and electronic equipment. So it reaches a part when the part carries an electrical or electronic function. Chemical rules can still apply to the same part.
What should we ask for instead of a CE mark?
Ask for the material grade, the finish, the drawing revision, an inspection record and a statement against the substance list you work from. That set is what an auditor can actually check.