EU REACH Certification

Reach is the abbreviation for the Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals (EC 1907/2006) issued by the European Union. This regulation came into force on June 1, 2007. It is one of the most complex chemicals management regulations in the history of the European Union and one of the most stringent chemicals management systems in the world.

The core objective of the REACH regulation is to protect human health and environmental safety while promoting the free trade of chemicals within the EU internal market and enhancing the competitiveness of the chemical industry. REACH overturned the previous approach of "government must prove chemicals are harmful before controlling them" and established the principle of "companies must prove chemicals are safe," shifting the responsibility for chemical safety management from the government to enterprises.

The REACH regulation contains four core mechanisms: Registration, Evaluation, Authorization, and Restriction. Registration requires manufacturers or importers to register chemicals placed on the EU market (annual production or import volume >= 1 ton) and submit safety data. Evaluation involves the European Chemicals Agency (ECHA) reviewing registration information. Authorization requires companies using Substances of Very High Concern (SVHC) to obtain special authorization. Restriction directly prohibits or limits the use of certain hazardous substances.

For manufacturers of electronic and electrical products, the most direct impact of REACH is the SVHC (Substances of Very High Concern) notification obligation and screening of high-concern substance content. To date, the SVHC list has been updated to over 240 substances, and is updated every six months (typically in January and July). If a product contains SVHC substances at concentrations exceeding 0.1 % (w/w), manufacturers must transmit safety information down the supply chain and provide relevant information free of charge upon consumer request. If the annual SVHC placement volume exceeds 1 ton, notification to ECHA is also required.

The REACH regulation has no product marking requirements. REACH compliance is achieved through supply chain information transmission mechanisms rather than through certification marks on products. Manufacturers and importers must transmit chemical safety information to downstream users and consumers via safety data sheets (SDS), material declarations, and technical documentation.

REACH SVHC testing is the most common REACH test item for electronic and electrical products. The test targets SVHC content in various homogeneous materials in products. As the SVHC list is continuously updated, test items must be based on the latest SVHC list. Test methods typically employ precision analytical techniques such as chromatography-mass spectrometry (GC-MS, LC-MS-MS) and inductively coupled plasma mass spectrometry (ICP-MS).

REACH Annex XVII restricted substances testing: Annex XVII lists substances restricted or banned in consumer products (approximately 70+ items), including carcinogenic, mutagenic, reprotoxic substances (CMR), persistent/bioaccumulative/toxic substances (PBT/v Pv B), etc. Common restricted substances include: AZO colorants, phthalates, polycyclic aromatic hydrocarbons (PAHs), formaldehyde, benzene, cadmium, nickel release, hexavalent chromium, organotin compounds, perfluorooctanoic acid (PFOA), etc. Each restricted substance has its corresponding test methods and limit requirements.

For different materials and product types, the focus of REACH testing varies: plastic products focus on phthalates, PAHs, AZO colorants, etc.; metal materials focus on cadmium, lead, hexavalent chromium, nickel release, etc.; textiles focus on AZO colorants, formaldehyde, organotin compounds, etc.; electronic components focus on lead, cadmium, mercury, PBB/PBDE, etc. Testing typically requires specialized chemical analysis laboratories using test methods recommended by CEN, ISO, or ECHA.

Supply chain information collection is the foundation of REACH compliance. The supply chain for electronic products is typically very complex, involving multiple tiers of suppliers. Manufacturers must collect material declarations and SDS from all suppliers to ensure a complete understanding of substance composition. Standardized material declaration templates (such as IPC-1752 A) and supply chain management tools (such as BOMcheck, UL Prospector, etc.) are recommended to improve information collection efficiency.

"0.1 % threshold" applies at the "article" level, an interpretation that became clear after the 2015 European Court of Justice (ECJ) ruling. That is, whether the SVHC concentration exceeds 0.1 %should be evaluated per article, not per entire product. For complex products composed of multiple articles (such as electronic products), each component (screws, housings, wires, etc.) must be evaluated individually for SVHC content. This significantly increases the complexity of REACH compliance assessment.