European Regulations Affecting Galvanized Steel Products
The European Union's environmental and chemical safety regulations continue to evolve, impacting manufacturers and specifiers of hot-dip galvanized steel products. Two key regulatory frameworks—RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, and Authorization of Chemicals)—occasionally require attention when galvanized products are destined for EU markets or specific end-use applications.
While these regulations primarily target electrical equipment and chemical substances, understanding their scope and applicability helps galvanizers and specifiers navigate compliance requirements efficiently. Most hot-dip galvanized structural steel products fall outside these regulatory frameworks, but specific applications warrant careful consideration.
RoHS: Restriction of Hazardous Substances
The RoHS Directive has been in effect since July 2006, targeting electrical and electronic equipment (EEE) such as computers, appliances, lighting fixtures, and similar products. The directive aims to reduce worker exposure to hazardous substances during equipment recycling by establishing maximum concentration values for restricted materials.
Evolution of RoHS Requirements
The original directive (2002/95/EC) restricted six hazardous substances. Subsequent revisions have expanded its scope. RoHS 2 (Directive 2011/65/EU) broadened the range of covered electrical products and introduced CE marking requirements. RoHS 3 (Directive 2015/863) added four phthalate compounds to the restricted list, bringing the total to ten regulated substances.
These ten substances include cadmium, lead, mercury, hexavalent chromium, two polybrominated compounds, and four phthalates. Each has specific maximum concentration limits ranging from 0.01 percent to 0.1 percent by weight.
Applicability to Galvanized Products
Most hot-dip galvanized steel products—such as bridge beams, light poles, guardrails, and structural components—fall outside RoHS scope because they are not classified as electrical or electronic equipment. However, galvanized products serving as fasteners, support structures, mounting hardware, or enclosures for electronic equipment may require compliance verification.
For galvanized products subject to RoHS, Lead Exemption 6(a)II provides crucial relief. This exemption permits up to 0.2 percent lead by weight across the entire steel component (not just the coating) for batch hot-dip galvanized steel. The exemption remains valid through December 31, 2026.
Lead Content in North American Galvanizing
North American galvanizers predominantly use Special High Grade (SHG) and High Grade (HG) zinc conforming to ASTM B6. This specification limits both lead and cadmium to a maximum of 0.003 percent each—well below RoHS thresholds. Research by the American Galvanizers Association demonstrates that the finished galvanized coating contains approximately 50 percent of the lead present in the zinc bath. With zinc containing 0.003 percent lead, the resulting coating typically contains approximately 0.0015 percent lead—far below the 0.2 percent threshold applied to the complete steel component.
Hexavalent Chromium Considerations
Hexavalent chromium represents another RoHS-restricted substance relevant to galvanizing operations. Facilities applying hexavalent chromium passivation treatments for products destined for EEE applications should maintain bath concentrations below 0.1 percent to ensure compliance. Many galvanizers have transitioned to trivalent chromium passivation systems, which are RoHS compliant and widely accepted as effective alternatives.
REACH: Registration, Evaluation, and Authorization of Chemicals
REACH has governed chemical substances in the EU since June 2007, administered by the European Chemicals Agency (ECHA). This comprehensive framework requires companies manufacturing or importing chemicals into the EU to register substances for risk evaluation. Chemicals posing serious risks to human health or the environment are added to the Substances of Very High Concern (SVHC) Candidate List.
As of June 2025, the SVHC list contains 250 entries, including carcinogens, reproductive toxins, mutagens, and persistent bioaccumulative substances. While zinc itself is not listed, lead, cadmium, and hexavalent chromium appear on the SVHC list.
REACH Classification of Galvanized Products
Hot-dip galvanized products are classified as articles under REACH regulations. This classification carries important implications for compliance requirements. The galvanized coating is not treated as a separate article but rather as an integral component of the finished product. Chemical content calculations consider the entire product mass (steel substrate plus coating), with SVHC thresholds applied at 0.1 percent of total product weight.
Because galvanized coatings represent a small fraction of total product mass and contain minimal concentrations of restricted substances, galvanized steel products are highly unlikely to exceed REACH thresholds. For companies not directly importing into the EU, REACH registration typically does not apply—compliance responsibility rests with EU customers or importers.
Documentation Requirements
Despite low risk of exceeding thresholds, galvanizers may receive requests from customers for documentation confirming SVHC content below 0.1 percent. These requests often arise from EU importers fulfilling their own compliance obligations. Galvanizers can address such requests by providing zinc specification conformance (ASTM B6) along with kettle assay reports demonstrating no SVHCs above regulatory thresholds.
EU Waste Framework Directive and SCIP Database
The EU Waste Framework Directive extends REACH requirements by mandating reporting of articles containing SVHCs above 0.1 percent to the SCIP (Substances of Concern In Products) database. While companies in North America are not directly responsible for SCIP submissions, their EU importers bear this obligation. Non-EU suppliers may be asked to provide SVHC information to support customer compliance efforts. Because the galvanized coating constitutes only a subcomponent of the finished article, documentation showing compliance with relevant specifications typically satisfies these information requests.
United States Regulatory Developments
Several U.S. states have introduced regulations similar to EU directives. California, New Jersey, Illinois, Indiana, Minnesota, New York, Rhode Island, and Wisconsin have implemented requirements limiting certain substances, mandating reporting, or both. Many states maintain electronic waste laws that include hazardous material restrictions.
No U.S. state has adopted REACH in its entirety, though several have developed chemical safety programs with similar objectives. California, Maine, Oregon, Washington, and Vermont have established initiatives promoting proactive chemical management and encouraging safer alternatives. Because requirements vary by jurisdiction, manufacturers should verify state-specific regulations applicable to their products.
Practical Compliance Approach
For most hot-dip galvanizing operations, RoHS and REACH present minimal compliance burden. The key considerations include verifying whether products fall within regulatory scope, understanding applicable exemptions, and maintaining documentation to support customer compliance efforts when requested.
RoHS Compliance Strategy
Most galvanized structural products require no action regarding RoHS. For products potentially subject to the directive—such as hardware for electronic enclosures—verify compliance through Lead Exemption 6(a)II and maintain zinc specification documentation. Products meeting exemption criteria should be accompanied by statements such as: \This product satisfies the requirements of RoHS Exemption 6(a)II for lead.\"
REACH Compliance Strategy
Galvanized products classified as articles under REACH rarely require registration or extensive documentation. When customers request SVHC information, provide zinc specification conformance documentation and kettle assay reports. For products containing passivation treatments, confirm the use of compliant chemical systems.
Additional Resources and Guidance
Detailed information about RoHS requirements, exemptions, and compliance procedures is available through the European Commission and UK government guidance documents. REACH registration, substance evaluation, and SVHC list updates are published by the European Chemicals Agency. The American Galvanizers Association provides technical guidance specific to hot-dip galvanizing operations and maintains resources addressing regulatory compliance.
For state-level requirements in the United States, manufacturers should consult individual state environmental agency websites for current regulations affecting electronic waste, hazardous substance restrictions, and chemical management programs.
Frequently Asked Questions
Do all galvanized products need RoHS or REACH compliance?
No. Most structural galvanized products fall outside these regulations. Compliance primarily affects products used in electrical equipment or those exported to EU markets.
How do I document compliance for EU customers?
Provide zinc specification conformance documentation (ASTM B6) and kettle assay reports showing substance concentrations below regulatory thresholds.
What is the status of hexavalent chromium passivation?
While still permitted under specific conditions, many galvanizers have transitioned to trivalent chromium systems that offer compliance advantages and equivalent performance.
Expert Support for Regulatory Compliance
V&S Galvanizing maintains comprehensive quality documentation and regulatory compliance records to support customer requirements. Our technical team stays current with evolving regulations and can provide the documentation necessary for products destined for regulated markets. We work proactively with customers to address compliance questions and ensure smooth project execution regardless of destination or end-use application.
For detailed regulatory references and updates, consult the original AGA guidance on RoHS and REACH compliance.
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