RoHS & REACH Compliant Silicone

RoHS and REACH Compliance for Silicone Rubber

Silicone rubber products exported to the European Union and many other global markets must comply with the RoHS Directive (restriction of hazardous substances in electrical and electronic equipment) and the REACH Regulation (registration, evaluation, authorisation and restriction of chemicals). Understanding the scope of each and what documentation buyers should request is essential for compliant product development and supply chain management.

RoHS: Restriction of Hazardous Substances

Current directive: EU RoHS 3 (Directive 2015/863 amending Directive 2011/65/EU), colloquially known as "RoHS 3."

Scope: Electrical and electronic equipment (EEE) sold in the EU. The directive applies to finished products — silicone rubber components in EEE must comply when the finished equipment is sold.

Restricted substances and maximum concentration values (MCV):

Silicone rubber base polymer: The PDMS backbone (Si–O–Si repeat unit) contains no restricted elements by design. Silicon, oxygen, carbon, and hydrogen are the only elements in the base polymer chain. Standard silicone rubber complies with all RoHS restrictions in the base polymer.

Where problems arise: Additives. Specifically:

• Pigments: Some older inorganic pigments contain lead, cadmium, or hexavalent chromium. Cadmium yellow and cadmium red are historical examples now banned. Modern food-grade and electronics-grade silicone pigments use RoHS-compliant inorganic pigments (iron oxide, titanium dioxide, chromium oxide Cr2O3).
• Flame retardants: Brominated flame retardants (PBBs, PBDEs) are explicitly prohibited. Silicone rubber with ATH (alumina trihydrate) or platinum-based flame retardants is inherently compliant. Verify that halogen-free status applies to any FR additive.
• Cure agents and crosslinkers: Standard platinum and peroxide cure systems do not introduce RoHS-restricted substances.

REACH: Registration, Evaluation, Authorisation and Restriction

Regulation: EC No 1907/2006 (REACH), as amended.

SVHC (Substances of Very High Concern): REACH requires that articles containing SVHC above 0.1 wt% of the article must be disclosed to customers and the ECHA (European Chemicals Agency) upon request. The SVHC Candidate List is updated twice per year by ECHA.

Silicone rubber and SVHC:

• PDMS base polymer: Not currently listed as SVHC.
• Cyclic siloxanes D4, D5, D6: D4 (octamethylcyclotetrasiloxane) and D5 (decamethylcyclopentasiloxane) are SVHC substances. D4 and D5 are present as residual trace components in PDMS polymer (typically <0.5 wt% combined). The SVHC article threshold is 0.1 wt% of the article. For most silicone rubber articles, D4+D5 content will be at or near this threshold — buyers should request SVHC declarations from their supplier.
• D6 (dodecamethylcyclohexasiloxane): Not currently listed as SVHC as of 2025.
• Tin catalysts: Certain organotin compounds used in condensation-cure RTV are SVHC (e.g., dibutyltin dilaurate). Addition-cure (platinum) systems do not use tin catalysts.

Documentation Buyers Should Request

1. RoHS Declaration of Conformity: Signed statement identifying the product, confirming compliance with Directive 2015/863, and identifying the relevant exemptions (if any) claimed.

2. REACH SVHC Declaration: Confirmation of SVHC content above/below 0.1 wt% threshold. If above threshold, identity and concentration of each SVHC substance.

3. Third-party test report: For supply chain assurance, request ICP-MS (inductively coupled plasma mass spectrometry) or XRF (X-ray fluorescence) test data for restricted heavy metals. XRF screening is acceptable for initial qualification; ICP-MS is required for confirmation testing.

Contact us to verify RoHS/REACH compliance documentation and request test reports for your specific silicone rubber compound and application.