I had this response from HSE. I have to say the distinction between solder and free cutting bars seems highly dubious:
Dear Neil,
There are restrictions on the placing on the market of metallic lead (as a substance), of mixtures containing lead (e.g., alloys) and to articles containing lead.
Restriction 30 in Annex XVII of REACH prohibits the supply to the general public of substances that could cause reproductive harm. This also applies to any mixtures containing these substances when they are present at or above certain concentration limits. For metallic lead a harmonised classification was agreed and published in 2016 [Regulation (EU) 2016/1179] and this came into effect on the 1st March 2018. This classification included reproductive harm. As a consequence, the sale to the general public of metallic lead (as a substance) or mixtures containing lead is prohibited. The concentration at which this kicks in depends on the form of the substance/mixture: for powders with a size of < 1mm the limit is 0.03%, for particles or other larger forms where the size is >= 1mm the limit is 0.3%. Such products can still be supplied to professional users, however, they are required to be marked visibly, legibly and indelibly with ‘Restricted to professional users.’
Restriction 63 applies to articles containing lead. Part of this restriction applies to items of jewellery and part applies more generally to items that could be placed into the mouth by children. There are certain exemptions and derogations for both parts. Examples of items covered by this restriction are given in the associated guidance at **LINK**.
For solder wire one can try to make an argument that the wire is what REACH calls an ‘article’ (in which case Restriction 30 would not apply , but Restriction 63 potentially would). An article is an object that during its production has been given a specific shape surface or design that is more important to its use than its chemical composition is. Examples of a metal article are a spoon, a pipe, a cable/rope, etc. In our view, the shape of solder wire is entirely irrelevant to its function. Solder wire is deliberately melted during its use and the form of a wire is purely for convenience. As such, soldering alloys containing lead are mixtures and Restriction 30 applies. The same would apply to casting alloys containing lead (at > 0.3%).
Where metals or alloys are supplied in the form of sheets, bars, rods, etc, then it may be possible to argue that they are articles. The ECHA guidance on substances in articles contains a flow diagram that considers the boundary between metals and alloys being substances/mixtures (see Appendix 4 and pages 78-82). Items such as lead sheets or lead bearing phosphor bronzes and steels may be being supplied in the form of articles. Whilst these may subsequently be cut or deformed to some degree, the basic shape is usually retained or remains important. Depending on the subsequent use Restriction 63 may apply to the items being produced. If the suppliers decides that the items are articles, then Restriction 30 wouldn’t apply.
Kind regards
REACH & CLP Helpdesk
Chemicals Regulation Division
HSE, Redgrave Court, Bootle, Merseyside L20 7HS