The Compliance Manager's Guide to Magnets

The regulatory surface of a magnet

Why this component in particular: the materials are the reason. NdFeB and SmCo magnets are built from rare earths and cobalt — supply chains that are geographically concentrated, politically instrumented, and specifically named in minerals-reporting frameworks. Add plating chemistries (substance declarations), imported origin (tariffs and country-of-origin), and strong fields in transport (dangerous goods), and one small part touches five compliance programs at once:

RoHS, REACH & substance declarations

• The magnet body is usually unproblematic; the questions live at the surface. Plating systems and their process chemistries, adhesives on assemblies, and pigments/markings are where substance questions concentrate — collect declarations that cover the part as shipped, coating included.
• Nickel surfaces earn a note: standard Ni-Cu-Ni plating is ubiquitous and lawful, but products with sustained skin contact face nickel-release considerations in some markets — a design conversation (epoxy or alternative coatings, per the coatings guide) rather than a paperwork one.
• REACH is a moving list. Candidate-list updates land twice a year; a declaration is a snapshot, not a property of the part. Date every declaration and tie the refresh cycle to list updates, not to the calendar anniversary of onboarding.
• Declarations follow the manufacturing site. A trader's declaration that doesn't name the factory inherits every weakness of trader documentation flagged in the supplier qualification guide — assembled paperwork, unverifiable claims. Require site-specific declarations for the parts that matter.

Conflict minerals & responsible sourcing

• SmCo puts cobalt in scope. Cobalt reporting (EMRT in most programs) applies to samarium-cobalt parts — the item that surprises teams who associate magnets only with rare earths. NdFeB grades can also carry cobalt additions; ask rather than assume.
• Classic 3TG rarely comes from the magnet itself, but assemblies do it for you: tin in solder, tungsten in balancing weights or crimped hardware around the magnet. Scope the reporting at the assembly level your customer actually buys.
• Rare earths increasingly ride the same rails. Formal conflict-minerals law doesn't cover Nd/Pr/Dy/Tb, but customer ESG programs, forced-labor due-diligence regimes, and import-scrutiny frameworks increasingly ask for rare earth chain transparency. The practical response is the same one quality demands: named manufacturing sites and material origin, which is why the compliance program and the qualification program should share a supplier file.
• Answer once, reuse everywhere: a maintained CMRT/EMRT package per supplier, mapped to your part numbers, turns each customer request from a project into an attachment.

Export controls & licensing

• The active regime is upstream of you: China's export licensing on rare earth materials and magnet products — expanded through 2025 — inserts a permitting step into the supply chain that shows up as lead-time variance and occasional allocation, not as a form on your desk. Compliance's job is visibility: which parts carry heavy rare earths (Dy/Tb — the SH/UH/EH temperature classes), which suppliers hold licenses, and what the realistic licensing clock adds — context in the supply chain guide.
• Your own exports need the ordinary discipline: magnets and magnet assemblies are mostly uncontrolled as such, but end-use and end-user screening still applies — high-performance magnets go into motors, guidance, and defense articles, and it's the application that trips control regimes, not the magnet. Screen and record like any other component with dual-use adjacency.
• Watch the policy calendar as a compliance input: new control rounds and tariff modifications arrive with weeks of notice and change both cost and paperwork. Assign the watch; feed it to procurement and planning — the same monitoring loop the tariffs guide recommends commercially.

HTS classification, origin & duty

• Classification is a defended position, not a guess. Magnets and magnet-bearing assemblies classify differently, and the difference carries duty consequences — document the rationale (what the article is, why the heading applies) so the answer survives an inquiry. The working arithmetic of the current tariff stack on Chinese-origin magnets lives in the tariffs & landed cost guide.
• Origin is substance-over-form. Third-country routing and light assembly steps don't move origin unless substantial transformation actually occurred — aggressive origin engineering on magnet assemblies is a compliance exposure wearing a savings costume. If the structure only works because of the declared origin, have counsel bless it before customs asks.
• Valuation includes what procurement negotiated: tooling paid separately, assists, and design work can belong in customs value — loop compliance into magnet tooling deals so the entry matches the contract.
• Keep the duty math auditable per part: HTS, origin, rate stack, and date — rates have changed repeatedly, and a landed-cost model with stale duty inputs misleads both finance and any post-entry review.

Dangerous-goods shipping

Magnetized material is the rare compliance topic where the physics is the regulation — the full rules are in the air shipping guide; the program view:

• The determination is per package, by measurement: field strength at defined distances from the package surface decides between unrestricted, UN 2807 magnetized material, and unacceptable-for-air — packaging method (spacing, shielding, orientation) is how a shipment moves down that ladder.
• Keep the measurement records with the shipping papers. The documented field check is the compliance artifact; “we always pack them that way” is not.
• Assemblies and machines count too: a crated machine with strong magnets inside is measured the same way — the classic surprise at the freight forwarder.
• Unmagnetized shipment erases the topic: where the process allows magnetize-after-assembly, air freight becomes ordinary freight — a design decision with a compliance payoff worth advocating for.
• Ground and ocean are lighter-touch but not zero: stray-field limits protect other cargo; the same packaging discipline serves every mode.

The audit-ready magnet file

One file per magnet part number, shared between compliance, quality, and procurement — because the evidence overlaps almost completely:

Related: tariffs & landed cost · shipping magnets by air · quality documentation guide