REACH Testing

REACH Testing (Registration, Evaluation, Authorization and Restriction of Chemicals) is a comprehensive regulation (EC 1907/2006) implemented by the European Union for chemicals and downstream articles containing chemicals. It aims to protect human health and the environment while facilitating the safe use of chemicals. The regulation entered into force formally on June 1, 2007, with a wide coverage scope. It applies not only to chemicals themselves but also consumer goods, industrial products containing chemical substances, etc. It is a critical compliance requirement that enterprises must satisfy to export products to the EU market.


The core framework of the REACH Regulation consists of "Registration, Evaluation, Authorization and Restriction of Chemicals", including the following key procedures:


  1. Registration
    Manufacturers or importers are required to submit registration dossiers to the European Chemicals Agency (ECHA) when the annual production or import volume of a substance (pure substance or substance contained in mixtures) exceeds 1 tonne. The dossiers shall cover physicochemical properties, toxicological data, intended uses and risk control measures of the substance to prove its safe use.

    • Registration is carried out in phases. The level of detail of test data and documentation required varies according to annual tonnage bands (1 tonne/year, 10 tonnes/year, 100 tonnes/year, 1000 tonnes/year, above 10000 tonnes/year) and risk classification of substances.

  2. Evaluation
    ECHA or competent authorities of EU Member States evaluate registered substances, including:

    • Dossier Evaluation: Verify the completeness and compliance of registration dossiers;

    • Substance Evaluation: Assess whether substances pose health or environmental risks, and require supplementary test data where necessary.

  3. Authorization
    Enterprises must apply for authorization to continue using substances classified as Substances of Very High Concern (SVHC) with available alternatives. Substances without obtained authorization are prohibited from production, import or use within the EU market.

  4. Restriction
    If a substance poses unacceptable risks to human health or the environment, the EU may ban or restrict its production, marketing and use via restriction provisions (e.g. restrictions on lead content in paints).


Under the REACH Regulation, Substances of Very High Concern (SVHC) are the core controlled substances, mainly including the following categories:


  • Carcinogenic, Mutagenic or toxic to Reproduction substances (CMR);

  • Persistent, Bioaccumulative and Toxic substances (PBT);

  • very Persistent and very Bioaccumulative substances (vPvB);

  • Other substances of equivalent serious hazard (such as endocrine disruptors).


The SVHC candidate list is dynamically updated by ECHA (as of May 2024, updated to the 29th batch with a total of 235 substances). Enterprises shall track updates of the list and fulfill the following obligations:


  1. Communication of information: If the SVHC content in articles exceeds 0.1% by weight, information on safe use shall be provided to customers and consumers;

  2. Notification Obligation: If the SVHC content in articles exceeds 0.1% by weight and the annual export volume exceeds 1 tonne, notification shall be submitted to ECHA within 6 months after the substance is included in the candidate list;

  3. Supply Chain Management: Enterprises shall confirm the presence and content of SVHC in products via testing or supplier declarations.


Scope of Application
  • Chemicals (pure substances, mixtures);

  • Electrical and electronic products (such as home appliances, mobile phones, computers, covering components including plastics, metals, coatings, etc.);

  • Textiles, garments and footwear (involving dyes, auxiliaries, adhesives, etc.);

  • Toys and children’s articles (involving plastics, rubber, coatings, etc.);

  • Furniture and construction materials (involving wood preservatives, adhesives, paints, etc.);

  • Automobiles and auto parts (involving plastics, rubber, metal treatment agents, etc.).

Regulation

Core Controlled Objects

Scope of Application

Core Purpose

REACH

Chemicals and SVHC substances (235 items, updated dynamically)

Nearly all products

Control risks throughout the entire lifecycle of chemicals

RoHS

10 hazardous substances contained in electrical and electronic products

Electrical and electronic equipment

Restrict hazardous substances in electronic waste

California Proposition 65

Chemicals known to cause cancer or reproductive toxicity

Consumer goods sold on the California market

Warn consumers of potential health risks

 

Service Process

1. Confirm Test Objects

Split test units according to product materials (such as plastics, metals, textiles, coatings, etc.), and different materials shall be tested separately.

2. Select Test Items

Tests are generally carried out against the currently valid SVHC candidate list. Full testing or targeted testing can be selected based on product characteristics and applications (e.g., electronic products focus on heavy metals, flame retardants, etc.).

3. Sample Preparation

Provide representative samples (approximately 50-100g for each test unit, subject to specific requirements of the testing laboratory) and ensure the samples are free from contamination.

4. Test Methods

Chemical analysis methods are adopted, as follows:

Heavy metals (such as lead, cadmium, mercury): ICP-MS (Inductively Coupled Plasma Mass Spectrometry), AAS (Atomic Absorption Spectroscopy);

Organic substances (such as polycyclic aromatic hydrocarbons, phthalates, flame retardants): GC-MS (Gas Chromatography-Mass Spectrometry), HPLC (High Performance Liquid Chromatography).

5. Issue Test Report

The testing laboratory issues a report based on test results, clarifying whether the content of each SVHC exceeds 0.1%, and providing compliance judgment.


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