RoHS, REACH & Conflict Minerals: Magnet Compliance

Good news first: a standard sintered NdFeB magnet — neodymium, praseodymium, iron, boron, minor dysprosium/terbium/cobalt additions, with NiCuNi or epoxy coating — contains none of the classic problem substances in its base composition, and compliant product is the industry norm. The compliance work for magnets is therefore mostly about verification and documentation: proving with certificates what the material declaration says, and watching a few specific exposure points (mainly in coatings) where non-compliant variants exist.

RoHS restricts ten substances in electrical and electronic equipment above defined maximum concentration values (0.1% w/w for most; 0.01% for cadmium): lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates (DEHP, BBP, DBP, DIBP).

Where magnets could have exposure

• Hexavalent chromium in coatings. The classic risk: older zinc-plating passivations used Cr(VI) chromates. Modern trivalent passivation is the compliant standard — but this is the number-one thing a RoHS certificate for a zinc-coated magnet is actually attesting to.
• Lead and cadmium as trace contaminants in platings or solders on magnet assemblies. Compliant plating lines control this; certificates and periodic XRF screening verify it.
• Phthalates in polymer content — relevant to bonded magnets (polymer-bound NdFeB/ferrite), adhesives in assemblies, and packaging, not to sintered metal parts.
• The magnet alloy itself is clean. Nd, Pr, Dy, Tb, Fe, B, Co, Al, Cu — none are RoHS substances.

What to require: a RoHS compliance certificate/declaration for the finished part number (alloy + coating as a system), reissued when the coating spec changes and referencing the current directive including the phthalate amendment.

REACH obliges suppliers of articles to disclose any Substance of Very High Concern (SVHC) present above 0.1% weight-for-weight, per the ECHA Candidate List — which is updated roughly twice a year and now runs to 240+ entries. For most buyers, the practical instrument is the supplier's SVHC declaration stating whether any candidate-list substance exceeds the threshold in the article.

• Standard sintered NdFeB with NiCuNi or epoxy coating: typically no SVHC above 0.1% — the declaration is a "none above threshold" statement against a stated Candidate List revision date.
• Watch items: lead (an SVHC) as trace content in certain platings or free-machining brass in assemblies; boric acid appears on the candidate list but sintered NdFeB contains boron as an alloyed compound, not boric acid — a distinction a competent declaration will make explicitly.
• Because the list moves, declarations date-stamp. Require the declaration to cite the Candidate List revision it was assessed against, and refresh declarations on a defined cycle (annually is common) or on list updates.
• SCIP database: if you place articles with SVHC >0.1% on the EU market, SCIP notification obligations may apply downstream — one more reason "none above threshold" documentation matters.

3TG — the classic conflict minerals

US Dodd-Frank §1502 and the EU Conflict Minerals Regulation cover tin, tantalum, tungsten, and gold (3TG). A sintered NdFeB magnet contains none of the 3TG in its standard composition — the honest answer on a CMRT (Conflict Minerals Reporting Template) for plain NdFeB is that 3TG is not intentionally added. Assemblies can differ: solder (tin), tungsten-alloy counterweights, or gold plating bring 3TG into scope, at which point smelter-list due diligence applies.

Extended minerals — where magnets are actually in scope

The Extended Minerals Reporting Template (EMRT) covers cobalt and natural mica — and cobalt is genuinely present in magnets: a few percent in many NdFeB grades and a principal constituent of SmCo. Responsible-sourcing expectations for cobalt (driven by DRC artisanal-mining concerns and battery-industry programs) increasingly flow down to magnet suppliers via the EMRT.

What to require: a completed CMRT (even when the answer is "not intentionally added" — customers' systems want the form, not an email), plus an EMRT when your program covers cobalt, with refresh on your standard annual campaign cycle.

• California Prop 65. Nickel (as in NiCuNi coatings) is a listed substance; whether a warning is required depends on exposure assessment for the finished consumer product. B2B components typically address this contractually with a Prop 65 statement identifying listed substances present.
• TSCA (US). Standard magnet constituents are established chemistry on the TSCA inventory; the live area is TSCA §6(h)/PBT rules and PFAS reporting — mostly relevant to certain coatings, lubricants, and packaging materials rather than the magnet alloy. A supplier statement covering TSCA §6 substances (e.g., PIP (3:1)) is now a routine ask from US OEMs.
• Halogen-free requirements. Electronics customers sometimes require halogen-free declarations; relevant to epoxy coatings and bonded-magnet binders, where compliant formulations are standard but should be stated.
• Packaging directives. EU packaging heavy-metals limits and wood-packaging ISPM-15 heat-treatment stamps for crated ocean freight — logistics-side items your forwarder and supplier handle, worth a line in the PO terms.

• IMDS (automotive). OEM programs require a full material declaration in the International Material Data System — every substance in the part, entered against the OEM's part number, GADSL-screened. Confirm at RFQ that your magnet supplier can author or support the IMDS entry; it's labor, and it's much easier when the supplier provides the substance breakdown of alloy and coating layers.
• ELV Directive. The automotive counterpart to RoHS (lead/mercury/cadmium/Cr(VI) in vehicles) — satisfied by the same coating discipline, declared through IMDS.
• Medical device programs layer on biocompatibility (ISO 10993 evaluation of patient-contacting coatings — parylene and gold being the usual choices) and increasingly EU MDR substance disclosure (CMR/endocrine disruptors above 0.1% in invasive devices). Coating selection and its documentation should be planned together — see the material comparison and your coating spec.
• PPAP integration. For automotive, the compliance documents ride inside the PPAP package (material certs, IMDS acceptance). Ask for them as PPAP elements rather than chasing them separately — our testing guide covers the measurement side of the same package.

The pattern to notice: declarations are part-number level and periodic; certificates are lot level and continuous. A supplier who provides both without friction has the systems you want behind your supply chain.