A mechanical clamp installed inside a wind turbine does not automatically become RoHS-scoped electrical and electronic equipment. REACH communication duties can still apply to the clamp body, polymer insert, coating or fastener as articles, while SCIP obligations arise under separate waste legislation. Procurement should therefore separate scope, substance evidence and notifier responsibility.
Do not request one generic ‘RoHS/REACH certificate’. First decide whether the supplied item is an article or complex object, whether the finished equipment falls within RoHS scope, and whether any Candidate List SVHC exceeds 0.1% w/w in a constituent article. Request dated, part-number-specific evidence and assign SCIP responsibility to the correct EU supply-chain actor.
- Best for
- EU-bound wind-project RFQs, supplier approval, material substitutions and compliance-document reviews for clamps, cleats, inserts, coatings and hardware.
- Not suitable for
- A legal opinion, laboratory chemical analysis, declaration for an unidentified part, or proof that a Weique product contains no restricted substance.
- Decision checks
- part number and revision, article hierarchy, Candidate List date, SVHC threshold basis, RoHS scope decision, homogeneous-material evidence, EU economic operator, SCIP duty and declaration issuer
- RFQ inputs
- market and end use, BOM, material and coating specifications, supplier declarations, analytical reports where required, EU importer or assembler, Candidate List reference date and change-control rule
§ 01 Separate the three questions
REACH Article 33 concerns information on Candidate List substances in articles. RoHS restricts substances in electrical and electronic equipment within its legal scope. SCIP is a notification system under the Waste Framework Directive. A single checkbox cannot answer all three.
§ 02 Decide RoHS scope before asking for conformity
Directive 2011/65/EU applies to defined categories of EEE and contains exclusions including certain large-scale fixed installations. A standalone mechanical clamp is not automatically EEE because it is installed in a turbine. The finished-equipment manufacturer or responsible EU operator should document the scope decision.
§ 03 Apply the REACH 0.1% threshold at article level
ECHA states that suppliers of articles containing a Candidate List substance above 0.1% w/w must provide sufficient safe-use information, at least the substance name. The EU Court confirmed that a constituent article does not lose this identity merely because it is assembled into a complex product.
§ 04 Do not confuse Article 33 with Article 7(2)
Article 33 supply-chain communication and Article 7(2) notification are different duties. ECHA lists additional quantity and exemption conditions for Article 7(2). Procurement should not turn the one-tonne condition into a reason to ignore Article 33 communication.
§ 05 Assign SCIP responsibility contractually
ECHA states that companies supplying qualifying articles on the EU market must submit SCIP information when Candidate List SVHC concentration exceeds 0.1% w/w. The RFQ should identify the EU importer, assembler or distributor responsible rather than assuming a non-EU component maker files every notification.
§ 06 Request evidence tied to the supplied configuration
A useful declaration identifies legal entity, part number, revision, materials or article groups, Candidate List reference date, applicable exemptions or scope rationale, signature and issue date. Generic website statements or undated certificates do not close substitution risk.
§ 07 Control changes after approval
Candidate List updates and material substitutions can change the conclusion. Require notification before changing polymer grade, pigment, plating, coating, adhesive or fastener source, and define when renewed supplier evidence or project review is needed.
§ 08 Evidence levels
| Evidence level | Use | Boundary |
|---|---|---|
| TESTED | Result matches the tested configuration. | Does not cover changed components or installation. |
| BATCH-TRACEABLE | Record links to the delivered lot. | Does not prove unrecorded system performance. |
| STANDARD-BASED | Official scope defines a method or decision system. | Does not select project criteria or prove this product passed. |
| PROJECT-SPECIFIC | Customer risk and drawings close the decision. | Cannot be generalized to another project. |
| INDICATIVE | Example or early screening logic. | Not an acceptance plan or guaranteed value. |
§ 09 Decision matrix
| Decision | Required evidence | Boundary |
|---|---|---|
| RoHS in scope | Finished-equipment scope record and material-level compliance evidence. | A component declaration does not decide equipment scope. |
| RoHS out of scope | Documented rationale from responsible market actor. | Out of RoHS scope does not remove REACH duties. |
| SVHC ≤0.1% w/w | Dated supplier evidence for each relevant constituent article. | Candidate List and BOM changes require review. |
| SVHC >0.1% w/w | Article 33 information and SCIP responsibility assessment. | Does not automatically prohibit sale. |
| Unknown composition | Escalate for supplier disclosure or risk-based analysis. | Do not convert absence of data into compliance. |
§ 10 Official sources and evidence boundary
These EU and ECHA sources directly support the legal scope and threshold statements. The application to a particular clamp supply chain remains project-specific and depends on article composition, market role, end equipment and current Candidate List.
- ECHA — Communication in the supply chain under REACH Article 33
- ECHA — Notification of substances in articles under REACH Article 7(2)
- ECHA — SCIP obligations for articles containing Candidate List SVHCs
- EUR-Lex — Directive 2011/65/EU on RoHS
- EU Court of Justice — 0.1% threshold applies to each constituent article
Clamp documentation package · Material traceability · Test-evidence guide · Wind turbine clamp systems
For the related release decision, use PFAS in Wind Turbine Clamp Materials: What Buyers Should Request.