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REACH and RoHS declarations for silicone

The polymer is not the problem. What gets a silicone part into a REACH question is almost always something added to it, and the declaration is only as good as the list behind it.

By Yude Technology Engineering Team Published 5 November 2026 7 min read
Applies to LSR, HCR and compression molding
Short answer

Under REACH, a silicone part must declare any Candidate List substance above 0.1% by weight of the article, per Article 33, and SCIP notification applies where that threshold is exceeded. Under RoHS, the ten restricted substances apply to electrical and electronic equipment, with limits of 0.1% by weight in homogeneous material, 0.01% for cadmium. Silicone polymer and platinum cure are rarely the risk; pigments, plasticisers, flame retardants and residual catalysts are where the exposure sits.

The polymer is not the risk

Silicone polymer, platinum catalyst and the usual fillers are not where a REACH or RoHS problem comes from. The exposure sits in what is added:

  • Pigments and masterbatches. Colour is the most common source of a restricted substance in an otherwise clean compound.
  • Plasticisers and processing aids. Less common in silicone than in PVC, but present in some soft compounds and in some masterbatches.
  • Flame retardants, in compounds formulated for electrical applications.
  • Residual catalysts and process residues, which is a question about the cure system as much as the formulation.

That distribution matters practically, because it means the declaration has to be built at the compound level, per grade and per colour. A generic "our silicone is REACH and RoHS compliant" statement is a claim about a material family, not about the part in the box.

REACH: the two obligations that apply to a part

Article 33 requires a supplier of an article to give the recipient enough information to use it safely where a Candidate List substance is present above 0.1% by weight of the article. That is a communication duty, not an approval — nothing is banned, but the customer has to be told.

SCIP requires that information to be notified to ECHA's database where the threshold is exceeded, and the SCIP number is increasingly requested alongside the declaration.

Separately, Annex XVII restrictions apply to certain substances in certain articles regardless of concentration — the polycyclic aromatic hydrocarbon entry for consumer articles that touch skin is the one most likely to reach a rubber part. And Annex XIV authorisation applies to a short list of substances that cannot be used without a grant.

0.1 % w/wSVHC threshold, per article weight
Article 33Duty to inform the recipient
SCIPDatabase notification above the threshold
Twice a yearTypical Candidate List update cadence

RoHS: ten substances, homogeneous material

RoHS restricts ten substances: lead, mercury, cadmium, hexavalent chromium, two brominated flame retardants, and four phthalates. Limits are 0.1% by weight in homogeneous material, with 0.01% for cadmium.

Homogeneous material is the key phrase and the one that changes the answer. The limit applies to a material that cannot be mechanically separated — the silicone compound itself, a pigment, a coating, an insert — not to the assembly averaged out. A part that is 99% clean silicone and 1% a non-compliant marking ink is a non-compliant part, because the ink is its own homogeneous material.

Exemptions exist and expire. For silicone parts, the relevant ones are rare, but if a supplier cites an exemption, ask for its entry number and expiry date rather than accepting the word.

What an auditable declaration contains

Element Why it matters
Part number and description A company-level statement cannot be traced to a shipment
Compound grade, colour and supplier This is where the substances live
Regulation and list version REACH declarations date quickly
Threshold basis (article weight or homogeneous material) The two are different calculations
Test data or formulation assessment "Assessed" and "tested" are not the same evidence
Lab, report number and date, where tested Makes the claim checkable
Exemptions claimed, with entry and expiry An unqualified exemption is a liability
Signatory and revision Someone accountable, and a version to compare

The two lines buyers most often skip are the threshold basis and the evidence type. A declaration that says "compliant" without saying whether it was assessed from the formulation or tested on the part leaves the customer unable to answer the next question in their own supply chain.

What we issue, and why per part

A declaration per part number, naming the compound grade and colour, the regulation and the Candidate List version, and the basis of the assessment. Not one certificate for the company, because the company makes several compounds in several colours and the answer differs between them. When a customer's auditor asks why a red part and a natural part carry different dates, the honest answer — a different masterbatch, reviewed at a different time — is much easier to defend than a single document that claims everything at once.

The four questions that settle it

  1. Is the part in RoHS scope at all? If it is not part of electrical equipment, RoHS is the wrong regulation and the declaration should say so rather than assert compliance with something that does not apply.
  2. Which Candidate List version does the REACH statement reference? If it is older than the latest update, ask for a refresh.
  3. Is the assessment formulation-based or tested? Both are legitimate; only one is checkable by a lab.
  4. Does the declaration name the colour? Colour is where the risk is, and a declaration without it is a declaration about a different part.

A supplier who can answer all four in a single reply has a compliance process. One who sends a PDF with a logo and the word "compliant" has a marketing document, and it will not survive the first serious audit in your own supply chain.

Frequently asked questions

Is silicone exempt from RoHS?

No, and the question is slightly upside down. RoHS applies to electrical and electronic equipment, so it reaches a silicone part when the part is a component of such equipment — a keypad, a seal in a connector, a gasket in a charger. Once in scope, the ten restricted substances apply at the homogeneous material level. Silicone compounds are usually compliant, but a coloured compound can carry a pigment that is not, which is why the declaration has to be per compound grade rather than per material family.

Does a REACH declaration expire?

The Candidate List is updated roughly twice a year, so a declaration is only current as of the list version it references. A declaration dated three years ago may be silent on substances added since. Ask for the list version or the date of the last review, and treat anything older than the latest update as a document that needs refreshing rather than a document that is wrong.

What does 0.1% by weight of the article actually mean for a small part?

It means the threshold is calculated against the weight of the part, not of the material lot. On a 2 gram part, 0.1% is 2 milligrams, which is small enough that a trace contaminant in a pigment masterbatch could matter. This is why the calculation has to be done on the compound formulation with real loading figures, not assumed from a safety data sheet.

Ask for the declaration with the part number on it

A declaration that names the part, the compound grade and the revision date. We issue them per part, not per company.

Request a Declaration