Two regimes, one supply chain
RoHS and REACH are often named together on a vacuum cleaner datasheet, but they work differently. RoHS is a product restriction: electrical and electronic equipment placed on the EU market must not contain listed substances above set limits in homogeneous materials, with some listed exemptions. REACH is a chemicals regulation: among other duties, suppliers of articles must pass information down the chain when an article contains a substance on the candidate list of substances of very high concern above a threshold of 0.1% by weight, and must notify authorities in some cases. Neither regime is a certificate that a plant can hold once and for all. Both depend on what goes into the machine and on the evidence the suppliers provide.
A vacuum is a good example of why. The housing is injection moulded plastic with colourants, flame retardants and fillers. The cord has a PVC or rubber sheath and copper conductors with a plug. The motor has windings, lacquer and bearings. The control board has solder, components and coatings. The filter has media and sealants, the hose has plasticisers, and the carton has inks and adhesives. Each material comes from a supplier, and each supplier must declare what is in it.
RoHS in general terms
RoHS restricts a short list of substances: lead, mercury, cadmium, hexavalent chromium, and the flame retardants known as PBB and PBDE, plus four phthalate plasticisers added later. The limits apply per homogeneous material, meaning each separable material in the product, not the average of the whole machine. For a vacuum, the typical points of attention are lead in solder and in PVC stabilisers, cadmium in pigments and plating, hexavalent chromium in surface treatments of metal parts, and phthalates in cable sheaths and flexible hoses. Compliance is shown through technical documentation, supplier declarations and, in many cases, screening or laboratory reports on representative materials. The declaration of conformity for CE usually lists RoHS among the directives applied.
REACH in general terms
REACH has many parts, but the one most relevant to a vacuum importer is the duty on suppliers of articles that contain substances on the SVHC candidate list. The list is updated at regular intervals, so a statement that a product contains no SVHC is only correct for a stated list version and date. If an article contains such a substance above 0.1% by weight, the supplier must give recipients enough information for safe use, and consumers can ask for it. An importer into the EU also takes on responsibilities for substances in articles when the importer is the supplier. Restricted substances listed in the REACH annexes apply too, which can include certain chemicals in plastics, dyes and surface coatings.
Where substances hide in a vacuum
| Component | Typical materials | What to ask the supplier |
|---|---|---|
| Housing and bin | ABS, PP, PC blends with colourants and flame retardants | Material declaration and colourant statement; recycled-grade source if used |
| Power cord and cable | PVC or rubber sheath, copper, plug | RoHS and phthalate statement for the sheath |
| Hose and attachments | EVA or PVC, plasticisers, rubber seals | Phthalate and SVHC statement for the compound |
| Motor and board | Windings, lacquer, solder, components | RoHS declaration for parts and solder alloy |
| Filters | Paper, glass fibre, PTFE or nonwoven, sealants | Adhesive and sealant declaration |
| Battery pack | Cells, nickel strips, plastics, labels | Battery regulation and substance statement; see battery pack |
| Packaging | Cartons, inks, foam, bags | Packaging material statement and recycling marks for the market |
Plastics deserve special attention when recycled grades are used. A recycled ABS or PP can carry traces of earlier uses, and the plant should describe the source, the grade and the screening done. See the notes on plastics in vacuum housings for the material side.
What evidence to collect
- A RoHS declaration or test summary for the model, stating the directive version and the date.
- Material declarations from the plastics, cable, hose and filter suppliers, tied to the grades actually used.
- A REACH SVHC statement that names the candidate list version, with a note on how updates are handled.
- A laboratory screening report on representative parts, where the importer or customer requires one.
- A traceability rule: if a material or a supplier changes, the plant must inform the buyer and update the declaration.
- The packaging statement, covering the ink, the carton and any plastic bag.
The desk verifies these as part of the document check at the testing and inspection stage, and a short list is attached to the purchase order. Vaculent holds no certificates; partner plant documents are verified per project.
Screening reports versus declarations
Declarations and laboratory reports do different jobs. A supplier declaration states what the supplier believes the material contains, and it is only as good as the supplier's own control. A screening report measures samples of the finished material, often with a quick method for the restricted elements and a follow-up chemical test where a result is borderline. Importers who sell through large retail chains tend to be asked for reports, while smaller sellers may rely on declarations backed by an occasional check. A sensible middle path is to ask for declarations on every model and to commission a report on the highest-risk parts, such as the cable sheath, the hose compound and any coloured or recycled plastic, whenever a supplier or compound changes.
Common problems in vacuum projects
The usual issues are modest but costly. A declaration for the model name on the datasheet that does not match the model on the order. A report for the rigid housing that ignores the cable and the hose. A colour variant whose pigment differs from the tested one. A change of PVC compound at the cable supplier after the test. An SVHC statement dated years ago that no longer refers to a current candidate list. None of these implies bad faith; they come from long chains and fast model changes. A regular refresh of the declarations, tied to the production batch, is the practical answer.
Other markets and where to go next
Outside the EU, chemical rules vary: the United Kingdom has its own versions, and North America has state-level rules on certain chemicals and labelling. The importer should check the markets in scope, and the desk will pass on the list to the partner plant. For approvals on the electrical side, read IEC 60335-2-2 explained and the certifications checklist. Send your target markets and materials through the quote form, and check reference timing and quantities on MOQ and lead time; the desk confirms everything in writing for each program.