RoHS and REACH Compliance in Sourcing Starter Motor Carbon Brushes and Relays

So I got a call last year from a guy in Florida. He'd been bringing in starter motors from a factory in Zhejiang for about two years. Parts were good, pricing was right. Then he got an order from a buyer in Germany. Big order. The buyer asked for one thing: RoHS and REACH certificates for the carbon brushes inside the starters.

He emailed his factory. They sent him a PDF with a stamp. Looked official. He forwarded it to the German guy. A week later, the German guy comes back and says, "This doesn't work for us. We need third-party lab reports, not a self-declaration."

That's the spot a lot of US importers find themselves in. You're focused on price, quality, getting containers on time. Then some buyer from across the ocean starts asking about chemical regulations, and suddenly you're lost.

Let me break down what I've figured out about this stuff, specifically for starter motor parts. I'm no lawyer, but I've been burned enough times to know a few things.

What the heck are these things anyway?

RoHS is the one that gets talked about more. It's an EU thing. Stands for Restriction of Hazardous Substances. Basically it says you can't put too much of certain bad stuff in electrical and electronic products. Lead, mercury, cadmium, hexavalent chromium, a few flame retardants, and some plastic softeners called phthalates.

REACH is different. Bigger. Stands for Registration, Evaluation, Authorization, and Restriction of Chemicals. Instead of just looking at the finished product, it looks at pretty much any chemical that goes into making it.

Somebody explained it to me once in a way that stuck. RoHS is a shopping list of bad things you can't put in your product. REACH is a whole library of bad things you have to tell people about if they're in there.

For starter parts, you're dealing with both. Carbon brushes, relays, all of it.

Carbon brushes are a headache

A carbon brush isn't just carbon. I thought it was for a long time. It's actually a mix. Graphite powder, sometimes copper, and various binders all pressed together. The graphite does the conducting and lubricates the commutator as it spins.

But here's where it gets messy. That copper in the brush? That can be a problem under RoHS because copper alloys are allowed to have a certain amount of lead, but there's an exemption. The problem is whether your brush counts as a "carbon brush" or a "copper brush." The rules are different. And it's not always clear which bucket you fall into.

I've seen test reports where a factory stamped "RoHS compliant" but the actual lab data showed lead levels way over the limit. The factory had just printed a certificate without testing. That happens a lot more than people think.

And testing carbon brushes isn't simple. Graphite can mess up the lead detection. A proper test uses something called ICP-MS, which is fancy lab gear. A handheld XRF gun isn't enough. If your supplier's "test report" came from a machine the size of a hairdryer, you might want to ask questions.

Relays have their own mess

Relays are also a headache. The copper terminals, the plastic housing, the flame retardants in the plastic, the solder on the circuit board inside. Every one of those pieces is a potential compliance risk.

I've seen relays where the PVC wire insulation had phthalate levels way over the limit. I've seen soldering that used lead-based solder because it's cheaper. I've seen plastic housings with cadmium that the factory didn't even know was there.

And under RoHS, you can't just test the whole relay as one piece. The lab has to take it apart. Copper goes in one pile, plastic in another, solder in another. Test each separately. That's what the regulation says.

What you actually need from your supplier

After watching a few guys figure this out the hard way, here's what I've learned.

You need two things. A third-party lab test report. And a declaration from the supplier.

The test report should come from a lab that's accredited, like ISO 17025. Not the factory's own "internal testing." Not a PDF they typed up themselves. A real lab with a real stamp that you could theoretically call and verify.

The declaration is a signed statement from the factory that the parts are compliant. But a declaration without test data is just words. I've seen too many importers accept a declaration and never ask for the backup.

For REACH, you need to know about SVHCs. Substances of Very High Concern. The list keeps growing. It's over two hundred substances now. If your product has any of them above a certain level, you have to tell your customer. That's the rule.

Some of the big European automakers are already requiring suppliers to report into SCIP, which is the EU database for tracking these substances. It's not coming. It's already here.

They do check

This isn't just paperwork. EU customs actually checks.

I looked at the numbers recently. In 2025, the EU Safety Gate system reported thousands of product violations. A bunch of them were Chinese-made products. Lead in soldering was one of the most common. Cadmium in plastics. Phthalates in cable insulation.

When they find a violation, the products get pulled off the market. They get destroyed. The company's name goes on a public list. And if you're the importer of record, that's on you. Your customer isn't going to care that the factory lied. They're going to care that you sold them non-compliant parts.

The EU also updates their rules all the time. RoHS exemptions get revised. The lead exemption for copper alloys was updated recently. If your part relied on an exemption that just expired, suddenly your "compliant" part isn't compliant anymore. You have to stay on top of it.

What to do if you're just a US importer

If you only sell to the US, you might be tempted to ignore all this. I get it. It's a lot of paperwork. It costs money. Your domestic customers aren't asking for it.

But here's the thing. Big US brands are starting to pay attention too. They have their own compliance requirements. Even if you're selling to a US distributor, they might eventually ask for this data because their customers in Europe or Asia are asking them.

The smart play is to treat compliance as a selling point, not a burden. Gather the data from your suppliers. Keep it in a folder. Test random batches yourself if you have the budget. When a potential customer asks for compliance documents, you want to be the importer who can hand it over without scrambling.

The guy from Florida who lost the German order? He fixed it. He found a new factory that provided real third-party test reports. He started sending those reports with every quote, even to his US customers. It became part of his pitch. "I've got the paperwork. These other guys probably don't."

That's the opportunity. A lot of suppliers are cutting corners on compliance. If you're not, you have something real to offer.

Bottom line

RoHS and REACH aren't going away. If anything, they're getting stricter. The testing requirements are getting more detailed. The list of regulated substances keeps growing.

For anyone sourcing carbon brushes or relays from China, here's what you need to remember.

Know what RoHS restricts. Lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates. Those are the main ones.

Know that REACH is bigger. It covers SVHCs, which are a lot and they keep adding more.

Don't accept a supplier's self-declaration without test data from a real lab.

Test the parts yourself if you can. Not every batch, but random samples. Verify what your supplier is telling you.

Keep your paperwork organized. When a customer asks, you want to answer in hours, not weeks.

The importers who treat compliance as a competitive advantage are the ones who will win the European accounts and the picky US buyers. The ones who ignore it will keep losing orders and wondering why.

It's not the fun part of the business. But it's the part that keeps you out of trouble. And in this line of work, staying out of trouble is half the battle.