CE marking, REACH and technical compliance: what an OEM must check with an external metal parts supplier

A European OEM incorporating metal parts into a finished product (machinery, medical device, vehicle) bears full responsibility for the compliance of those parts with EU directives — even if the parts come from an external supplier. This article explains what needs to be checked before accepting a new supplier for CNC machining or laser sheet metal cutting, whether from Romania or outside the EU.

CE marking: what it means for a component part

A component part (semi-finished or with a technical function, but which is not an autonomous finished product) does not receive a separate CE mark. The responsibility transfers to the OEM integrating the part. However, the supplier must provide sufficient documentation for the OEM to be able to draw up their own CE declaration: material 3.1 certificates, testing reports, REACH, RoHS, conflict minerals declarations.

REACH: substances that cause problems

• Lead in free-machining alloys (0.1% limit in articles)
• Cadmium in coatings (prohibited in most applications)
• Hexavalent chromium in passivations (mandatory replacement with trivalent Cr3+)
• PFAS compounds in coolants and lubricants

A serious supplier has a quarterly updated REACH matrix and automatically reports any SVHC substance over 0.1% w/w. Mepro Sisteme maintains a digital traceability system that allows for the generation of a REACH report for any batch delivered in the last 36 months, in less than 24 hours.

RoHS and the ELV directive

For parts intended for electrical and electronic equipment (RoHS) or vehicles (ELV), restrictions are even stricter. Request signed batch declarations from the supplier, not general "company" certificates. The difference matters during an audit.

Mandatory batch documentation

• Material certificate 3.1 conforming to EN 10204
• Dimensional report (FAI or full inspection per AQL)
• Signed REACH/RoHS/ELV declaration
• Conflict minerals declaration (3TG)
• Potentially: EN ISO 3834 welding certificate, NDT report, passivation certificate

“Compliance is not a cost — it’s insurance. You pay little with each delivery, but it saves you from a single lawsuit that could shut down your factory.”

Why a Romanian supplier scores well here

Romanian suppliers natively operate under EU legislation — all prohibited substances are already eliminated, certificates are in standard European format, and conformity audits are part of the ISO 9001 routine. For European OEMs, this "born compliant" aspect eliminates dozens of hours of verification per new supplier.