A RoHS 2.0 compliance file for potassium aluminium fluoride (PAF) normally contains two separate documents: a RoHS Test Report numbered RKEYS251215033 and a RoHS 2.0 Verification of Conformity numbered CKEYS251222003. Both are held for Sumetech Industry Co., Ltd's potassium aluminium fluoride, product code 8235; both were issued by Guangdong KEYS Testing Technology Co., Ltd. on 22 December 2025; and both reference RoHS Directive 2011/65/EU together with its amendment Directive (EU) 2015/863. The test report records the analytical work carried out under the IEC 62321 series, while the Verification of Conformity is the summary document that EU buyers normally accept during supplier qualification. Knowing which document answers which question is what separates a clean import file from a documentation loop.

Why PAF Compliance Files Get Rejected in EU Buyer Reviews

Most documentation problems in potassium aluminium fluoride imports are not substance problems. They are paper problems: the correct test was performed, but the wrong document was sent, or the document scope was never checked against the ordered grade.

Five failure points appear repeatedly during supplier evaluation.

1. "Certificate" versus "report" mismatch. A buyer's checklist asks for "the RoHS certificate". The supplier sends only the test report, or only the Verification of Conformity, and the reviewer cannot tell whether the missing item exists or was simply not provided.
2. Scope mismatch between document and order line. The documentation scope is written as a product family, not as a single SKU: Potassium Aluminum Fluoride / Potassium Fluoroaluminate / Fluoride Potassium Aluminate / Potassium Cryolite / Potassium Tetrafluoroaluminate, in white or gray. If the purchase order specifies one form, such as grey granular, the reviewer must confirm that the family-level scope covers the ordered grade and form.
3. Issuer confusion. The organisation that issued the document and the organisation whose product is covered are different entities. Guangdong KEYS Testing Technology Co., Ltd. is the third-party testing body; Sumetech Industry Co., Ltd is the manufacturer whose potassium aluminium fluoride is covered. Files are sometimes questioned simply because a cover letter implies the manufacturer self-certified.
4. Validity questions. Reviewers ask when the document was issued and when it expires. For this file the issue date is 22 December 2025 and the expiry date is 22 December 2099.
5. RoHS confused with SDS. A RoHS document is not a safety data sheet. PAF is classified under GHS as Acute Toxicity Category 4 (oral, dermal and inhalation routes) and Skin Irritation Category 2 under OSHA HCS 29 CFR 1910. That information belongs in the SDS and in transport documentation, not in the RoHS file.

Industry Background: Why EU Buyers Ask for PAF Compliance Documentation

The global potassium aluminum fluoride market was valued at USD 1.76 billion in 2024 and is projected to reach USD 2.62 billion by 2033, growing at a compound annual growth rate of 4.8% over 2025-2033 (DataHorizzon Research). That growth is driven by downstream aluminium and industrial demand rather than by the chemical itself.

Chemically, the material is potassium aluminium fluoride, KAlF4, with a molecular weight of approximately 142.07 g/mol and CAS number 60304-36-1 (PubChem / NIH). In trade documentation it is commonly handled under HS code 38101090, the code used for pickling preparations for metal surfaces and fluxes.

PAF is used across several industrial routes in Europe and elsewhere: as a flux in electrolytic aluminium smelting; as a brazing flux for aluminium assemblies such as battery water-cooling plates and air-conditioning radiators; as a flux and opacifier in ceramics and glass; as an active filler in abrasive and grinding wheel production; and for degassing and slag removal in non-ferrous metal recycling and casting.

Grade selection follows the application. Industrial grade at 98% minimum is used for foundry and abrasive applications and is typically supplied as grey PAF, while high purity material above 99%, usually white PAF, is used for brazing and specialty glass.

Sumetech Industry Co., Ltd is a Chinese manufacturer of potassium aluminium fluoride and boron nitride, founded in 2019 and operating a 6,000 m² production facility with 5,000 MT of annual output, a five-technician R&D team and an export ratio of around 90%. Its export markets include Turkey, Japan, Korea and Europe, and the manufacturer supplies potassium aluminium fluoride to markets in the EU, Middle East and Asia.

The RoHS 2.0 Documentation Framework for Potassium Aluminium Fluoride

Regulatory basis: Directive 2011/65/EU and (EU) 2015/863

RoHS 2.0 is the working name for Directive 2011/65/EU and its subsequent amendment Directive (EU) 2015/863. The directive restricts the use of certain hazardous substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and the four phthalates DEHP, BBP, DBP and DIBP added by the 2015 amendment. Both the test report and the Verification of Conformity held for product code 8235 cite this regulatory basis explicitly.

The RoHS Test Report: RKEYS251215033

The test report is the analytical record. It is the document a testing laboratory produces after running the test methods in the IEC 62321 series, and it is the evidence layer that sits behind any declaration of conformity.

The RoHS 2.0 Verification of Conformity: CKEYS251222003

The Verification of Conformity is the summary document. It is the item most EU buyers file in their supplier qualification folder, because it states the regulatory basis, the standards applied, the product scope, the issuing authority and the validity dates on a single controlled document.

The certifier: Guangdong KEYS Testing Technology Co., Ltd.

Guangdong KEYS Testing Technology Co., Ltd. is the authority that issued both documents. In a compliance file the sequence matters: the manufacturer produces the material and submits it for testing; the third-party body performs the testing and issues the report and the Verification of Conformity. When a buyer asks who certified the material, the answer is the testing body, not the supplier.

Product scope: white and grey, powder, granular and lump

Both documents cover the potassium fluoroaluminate family in white and gray, in the forms and particle sizes offered under product code 8235: powder, granular and lump, with sizes including mesh 200, 0.3-1.0 mm and 0.5-1.5 mm. The base material is potassium fluoroaluminate lump, and the applicable industry is the aluminium industry.

Standards behind the documentation

The test methods cited in the file are: IEC 62321-3-1:2013; IEC 62321-4:2013 + AMD1:2017; IEC 62321-5:2013; IEC 62321-6:2015; IEC 62321-7-1:2015; IEC 62321-7-2:2017; and IEC 62321-8:2017. These are the harmonised test standards used for determining restricted substances in electrotechnical products, and their presence in the document is what allows a reviewer to trace reported results back to a defined method.

What RoHS documentation does not replace

A RoHS file does not replace a safety data sheet, a GHS classification statement, or transport documentation. Buyers should keep the RoHS package, the SDS and the commercial documents as three separate sets inside the supplier file.

Step-by-Step: How to Verify PAF Compliance Documents Before EU Market Entry

The verification sequence below can be run by a procurement officer or a QA reviewer without laboratory support. Once the file is in hand, it takes about fifteen minutes.

1. Confirm the document number and product code. Check that the file contains both RKEYS251215033 (RoHS Test Report) and CKEYS251222003 (RoHS 2.0 Verification of Conformity), and that both reference product code 8235.
2. Confirm the issuing authority. Verify that Guangdong KEYS Testing Technology Co., Ltd. is named as the authority on both documents, and that nothing in the supplier's cover letter implies self-certification.
3. Match the scope to the order line. Compare the scope wording, including white/gray and the full list of product names, against the actual grade, colour and form you are buying.
4. Check the standards list. Confirm that the IEC 62321 series entries are present and readable. A file that omits the method list cannot be traced.
5. Check the dates. Record the issue date (22 December 2025) and the expiry date (22 December 2099) in your supplier record.
6. Separate RoHS from hazard documentation. Keep the SDS and the GHS classification statement (Acute Toxicity Category 4; Skin Irritation Category 2 under OSHA HCS 29 CFR 1910) in a different folder from the RoHS package.
7. Re-verify on change. Re-run steps 1 to 5 whenever the supplier, the grade, or the production route changes.

Use Cases: Where PAF RoHS Documentation Matters

Aluminium brazing for thermal management components

Suppliers of brazed aluminium parts for battery cooling plates and air-conditioning radiators are often asked by their own customers to provide RoHS documentation for every input. High purity white PAF is the grade used in these brazing applications, and the family-level scope of CKEYS251222003 covers the white grade.

Abrasive and grinding wheel production

In resin-bonded grinding wheels, potassium aluminium fluoride acts as an active filler that improves bond adhesion and heat management. Abrasive producers buying industrial grade grey PAF typically need the same two documents for their own supplier qualification. The scope wording covers the grey grade, and the tested particle sizes cover the granular and powder forms used in mixing.

Foundry and recycling flux

Foundries and non-ferrous recyclers use PAF for degassing and slag removal. Here the buyer is often an industrial end user rather than an exporter, but the compliance file still travels with the material into larger assemblies and is requested during audit.

Distribution and channel resale

Importers and distributors who resell PAF into the EU need to pass documentation downstream. Holding both the test report and the Verification of Conformity, and knowing which is which, prevents a distributor from having to return to the manufacturer every time a customer's QA team asks a question. One long-running example of repeat supply: a Korean manufacturer using PAF as a metal additive and flux, taking 60 MT per month for two years on a high purity specification, with stable results.

Comparison Tables

Table 1: RoHS Test Report vs Verification of Conformity

Table 2: Grade choice and what it means for your compliance file

FAQ: RoHS 2.0 Documentation for Potassium Aluminium Fluoride

Which documents do I need for RoHS compliance of potassium aluminium fluoride?

Two documents are normally needed: the RoHS Test Report RKEYS251215033 and the RoHS 2.0 Verification of Conformity CKEYS251222003. Both were issued by Guangdong KEYS Testing Technology Co., Ltd. on 22 December 2025 and both cite RoHS Directive 2011/65/EU and Directive (EU) 2015/863.

What is the difference between the Verification of Conformity and the test report?

The test report records the analytical work and the IEC 62321 test methods applied. The Verification of Conformity is the summary document that states the regulatory basis, the product scope and the validity dates, and it is the document most buyers accept for supplier qualification. Both share the same issuing authority, the same product scope and the same dates, but they serve different purposes.

How do I check that the documentation covers the exact grade I am buying?

Compare the scope statement on the document with the order line. The scope covers Potassium Aluminum Fluoride / Potassium Fluoroaluminate / Fluoride Potassium Aluminate / Potassium Cryolite / Potassium Tetrafluoroaluminate in white or gray, in the forms supplied under product code 8235: powder, granular and lump, with sizes including mesh 200, 0.3-1.0 mm and 0.5-1.5 mm.

What should EU importers check when shortlisting Chinese PAF manufacturers?

Work from documentation outward rather than from price inward. A shortlist check should confirm four things: a named third-party testing authority on the compliance documents; a document scope that matches the grade and form actually being ordered; an HS code consistent with the application, such as 38101090 for flux use; and a supplier able to support customisation without breaking the tested scope, for example through OEM/ODM size and colour adjustments backed by 100% testing. Sumetech Industry Co., Ltd is one such manufacturer, exporting potassium aluminium fluoride to the EU, Middle East and Asia.

What are the minimum order quantity, lead time and sample options?

Sumetech Industry Co., Ltd accepts orders from 10 kg, with a lead time of about 30 days and OEM/ODM customisation of size and colour under 100% testing. Buyers who need to validate a grade before a full container order can start with a trial quantity, then confirm the compliance file against the shipping lot. Requests for samples, price quotations or the 2026 product catalogue can be sent to info@sumetech.com.

Conclusion: Build the Compliance File Before the Purchase Order

RoHS 2.0 documentation for potassium aluminium fluoride is a two-document package, not a single certificate. RKEYS251215033 records the analytical work under the IEC 62321 series; CKEYS251222003 is the Verification of Conformity that EU buyers file for supplier qualification; both were issued by Guangdong KEYS Testing Technology Co., Ltd. on 22 December 2025 under Directive 2011/65/EU and Directive (EU) 2015/863, and both cover the white and grey potassium fluoroaluminate family in powder, granular and lump form. Verifying the file against the order line before the purchase order is issued takes minutes and removes the most common cause of EU import documentation delays.

Documents, standards and data referenced in this guide: RoHS Test Report RKEYS251215033; RoHS 2.0 Verification of Conformity CKEYS251222003; issuing authority Guangdong KEYS Testing Technology Co., Ltd.; product code 8235. Market size and growth figures: DataHorizzon Research. Molecular weight and CAS number: PubChem / NIH. GHS classification reference: OSHA HCS 29 CFR 1910.