Does a brass fitting need to be RoHS compliant?

RoHS applies only to electrical and electronic equipment (EEE). A brass plumbing or HVAC fitting used solely as a fluid control component does not require RoHS compliance. RoHS only becomes relevant when brass is incorporated into an EEE product (e.g. a brass terminal on a circuit board assembly). If you are unsure, Brassland can provide a RoHS declaration regardless, using Exemption 6(c) for standard leaded brass.

Is brass REACH compliant?

Brass alloys (CW617N, CW602N, CW614N) are not subject to REACH registration as they are metals supplied as articles, not as chemical substances. The primary REACH obligation is Article 33: if any SVHC is present above 0.1% w/w, the supplier must communicate this to customers on request. Brassland issues proactive REACH compliance statements that address Article 33 obligations for all standard alloys.

What is a CMRT and when is it required?

A CMRT (Conflict Minerals Reporting Template) is a standardised document from the Responsible Minerals Initiative (RMI) used to report whether a product contains tin, tantalum, tungsten or gold (3TG) sourced from conflict-affected regions, primarily the DRC. US-listed public companies must file a Form SD with the SEC if their products contain 3TG. Brass fittings contain copper and zinc — not 3TG — so they typically fall outside CMRT scope. Brassland provides a written CMRT scope determination letter for customers who need to document this.

What is the SVHC Candidate List?

The SVHC (Substances of Very High Concern) Candidate List is published by ECHA under the REACH Regulation. It currently contains 240 substances. If any SVHC is present above 0.1% w/w in an article, the supplier must communicate this to customers under Article 33. Brassland monitors the Candidate List at every update (twice yearly) and issues updated compliance statements within 45 days of any change affecting supplied products.

Brass Fittings Compliance Centre: RoHS, REACH, CMRT, Prop 65

Q: What compliance certifications do brass fittings need?

The required compliance documentation depends on your destination market. For the EU: RoHS Declaration (if used in electrical equipment), REACH Article 33 statement, CE marking if the fitting falls under PED or construction products regulation. For the USA: California Prop 65 compliance documentation, CMRT (Conflict Minerals Reporting Template) for listed companies under Dodd-Frank. All markets increasingly require SVHC substance declarations. Brassland provides documentation for all of these on request.

This compliance centre is designed to serve procurement officers, quality engineers, importers, and compliance teams who source brass, copper or aluminium fittings from India. Each regulation is explained in plain language with references to the authoritative source text — not just marketing claims. Every page includes downloadable compliance statements from Brassland and direct links to the EU Official Journal, ECHA, the SEC, and OEHHA so you can verify everything independently.

Compliance Guides by Regulation

🇪🇺

EU DirectiveEEE

RoHS — Restriction of Hazardous Substances

Directive 2011/65/EU restricts 10 hazardous substances in electrical and electronic equipment. Brass falls under Exemption 6(c) — up to 4% lead in copper alloys. Valid until June 2027.

Full RoHS guide for brass →

⚗️

EU RegulationChemicals

REACH — Registration, Evaluation, Authorisation

EC 1907/2006. Brass fittings are "articles" — not subject to registration. Article 33 SVHC obligations apply if any substance on the 240-item Candidate List exceeds 0.1% w/w.

Full REACH guide for brass →

⛏️

US (SEC)EU Reg.

Conflict Minerals — CMRT & Dodd-Frank

Section 1502 of Dodd-Frank requires SEC-reporting companies to disclose use of tin, tantalum, tungsten and gold (3TG) from conflict regions. Brass fittings contain Cu+Zn — not 3TG.

Full CMRT guide for brass →

⚠️

CaliforniaUS Import

California Proposition 65

Safe Drinking Water and Toxic Enforcement Act. Lead and other chemicals in brass fittings trigger Prop 65 obligations for California sales. Safe harbour limits, NSF 61 & 372 connection explained.

Full Prop 65 guide for brass →

🔬

ECHAREACH Art.33

SVHC Candidate List — Substances in Brass

ECHA's Candidate List of 240 Substances of Very High Concern. Which ones appear in brass and copper alloys? Article 33 thresholds, SCIP database obligations, and monitoring commitment.

Full SVHC guide for brass →

Which Compliance Documents Do You Need?

Use this quick-reference matrix to identify what documentation to request from your brass fitting supplier based on your market and product type.

Market / Use Case	RoHS Decl.	REACH Art. 33	CMRT	Prop 65	SVHC Statement
EU — Plumbing / HVAC fittings	Optional	Required	N/A	N/A	Required
EU — EEE components (electronics)	Required	Required	N/A	N/A	Required
USA — General industrial / commercial	Optional	N/A	If SEC-listed	If CA sales	N/A
USA — California market / water fittings	N/A	N/A	N/A	Required	N/A
USA — SEC-listed OEM manufacturer	Optional	N/A	Required	If CA sales	N/A
UK post-Brexit	UKCA RoHS	UK REACH	N/A	N/A	UK REACH
Australia / Canada / GCC	Best practice	Best practice	N/A	N/A	Best practice

✅ Brassland can provide all of the above

We issue RoHS declarations, REACH Article 33 statements, CMRT scope determination letters, Prop 65 compliance notices and SVHC monitoring confirmations on request. Contact us and specify which documents you need — most are issued within 2 business days.

Downloadable Compliance Statements

📄

RoHS Compliance Statement

Directive 2011/65/EU · Exemption 6(c) · CW617N & CW602N

View RoHS page & statement →

📄

REACH Compliance Statement

EC 1907/2006 · Article 33 · SVHC Candidate List 2025

View REACH page & statement →

📄

Conflict Minerals Scope Letter

CMRT v6.0 · Dodd-Frank 1502 · EU CMR 2017/821

View CMRT page & statement →

📄

California Prop 65 Notice

OEHHA Safe Harbour · Lead & DEHP thresholds

View Prop 65 page & notice →

Why This Compliance Hub Exists

Most brass fitting suppliers hand over a one-page PDF that says "our products comply with RoHS and REACH" — with no substance behind it. That document satisfies no auditor, passes no regulatory check, and gives procurement teams nothing to act on.

This compliance centre was built to be different. Every claim links to the original regulation text. Every exemption cites its legal basis. Every threshold references the authoritative source — ECHA, the EU Official Journal, the SEC, OEHHA. Our goal is to help you understand the regulations well enough to assess any supplier's claims, not just ours.

We are a precision brass and copper fitting manufacturer based in Jamnagar, Gujarat — the centre of India's brass manufacturing industry for over a century. We export to 40+ countries. Compliance is not an afterthought for us; it is the foundation on which long-term export relationships are built.

Key Regulatory References

🇪🇺 RoHS Directive 2011/65/EU — Official text at EUR-Lex — Restriction of Hazardous Substances in Electrical and Electronic Equipment
🇪🇺 REACH Regulation EC 1907/2006 — Official text at EUR-Lex — Registration, Evaluation, Authorisation and Restriction of Chemicals
🔬 ECHA SVHC Candidate List — Live list at ECHA.europa.eu — 240 Substances of Very High Concern (updated January & July)
🇺🇸 Dodd-Frank Act Section 1502 — SEC Final Rule 34-67716 — Conflict minerals disclosure for SEC reporting companies
🇪🇺 EU Conflict Minerals Regulation 2017/821 — Official text at EUR-Lex — Supply chain due diligence for 3TG minerals
🇺🇸 California Proposition 65 (Safe Drinking Water and Toxic Enforcement Act of 1986) — OEHHA Official Page — Listed chemicals and safe harbour levels
🔬 ECHA SCIP Database — ECHA SCIP Overview — Substances of Concern In articles, as such or in complex objects (Products)
🌐 Responsible Minerals Initiative (RMI) — CMRT Template & Guidance at RMI — Official CMRT v6.0 template and smelter lists

Frequently Asked Questions

What compliance certifications do brass fittings need? +

It depends on your destination market and end use. For EU plumbing and industrial applications: a REACH Article 33 statement and SVHC declaration are the minimum. For EU electrical and electronic equipment: add a RoHS declaration. For US sales to California: Prop 65 compliance documentation. For SEC-listed US companies with 3TG in their supply chain: CMRT. Brassland can provide all of these — contact us with a list of what your auditor or customer requires.

Is Indian brass compliant with EU regulations? +

Yes. EU compliance regulations (RoHS, REACH) apply to the product itself — not the country of manufacture. Brass fittings from India manufactured from the same alloys as European producers (CW617N, CW602N, CW614N) are subject to identical regulations and can be equally compliant. What matters is the alloy composition, the documentation provided, and whether the supplier's quality system is auditable. Brassland manufactures to EN, DIN and BS alloy standards and provides full compliance documentation.

How often does ECHA update the SVHC Candidate List? +

ECHA updates the Candidate List approximately twice per year — typically in January and June/July. The list currently (January 2025) contains 240 substances. Brassland monitors every update and will proactively notify affected customers within 45 days of any change that affects the compliance status of supplied products, consistent with our Article 33 obligations.

What alloys does Brassland supply and are they all compliant? +

Brassland primarily supplies CW617N (free-machining brass, ~2% Pb), CW602N (DZR low-lead brass, <0.3% Pb), CW614N (high-tensile brass, ~3.5% Pb), and copper alloys C101/C102. For RoHS: CW617N and CW614N are compliant under Exemption 6(c) for EEE use; CW602N is compliant under the general 0.1% limit. For REACH: all alloys are articles and not subject to registration; Article 33 applies to CW617N and CW614N due to lead content. For Prop 65: leaded alloys require a Prop 65 warning for California sale. See each regulation's page for detail.

Does Brassland have ISO 9001 certification? +

Yes. See our Certifications page for full details on our quality management system, test capabilities, and supporting documentation. ISO 9001 certification provides the quality management framework within which our compliance documentation is generated and maintained.

⚠️ Note on regulatory changes

Environmental regulations for industrial products are updated frequently. Exemption 6(c) under RoHS is valid until June 2027 pending renewal. The SVHC Candidate List is updated twice yearly. California Prop 65 lists are updated annually. The information on this site is reviewed at every major regulatory update, but always verify against the primary source links provided on each page before making compliance decisions.

Brass & Copper Fittings Compliance: Everything You Need to Know