REACH Testing

The REACH regulation applies to virtually all consumer products in the EU market, including but not limited to: electrical and electronic products (plastic, metal, rubber parts, etc.), toys and children's products, textiles and clothing (including coated and printed materials), jewelry and accessories, furniture and home goods, automotive parts, building materials, cosmetic ingredients, and packaging materials. REACH controls chemicals in products through three tiers: Registration (chemical substances with annual production exceeding 1 tonne must be registered), Restriction (Annex XVII restricted substances must not exceed limits), and Authorisation (SVHC listed substances require notification or authorisation application). For consumer product exporters, the primary focus is on compliance with the SVHC list and Annex XVII restricted substances list.

The SVHC (Substances of Very High Concern) list is regularly updated by ECHA (typically twice per year). As of the latest 2023 update, the SVHC list includes over 235 chemical substances.

SVHC notification obligation: When the concentration of an SVHC substance in a product exceeds 0.1 % (weight percentage, w/w), the supplier must provide sufficient information to downstream recipients (manufacturers/importers/distributors) to ensure safe product use, at minimum including the substance name. Upon consumer request, information must be provided free of charge within 45 days. If the SVHC substance content in a product exceeds 0.1 % and the annual import volume exceeds 1 tonne, notification to ECHA is required.

REACH Annex XVII (Restricted Substances List) sets explicit restrictions on the use of specific chemicals in consumer products. As of 2023, Annex XVII includes over 70 entries.

Uses XRF for non-destructive rapid screening (suitable for lead, cadmium, bromine, etc.). Materials with positive XRF screening results undergo precise chemical analysis.

3. Homogeneous Material Disassembly REACH testing must be performed at the homogeneous material level. A homogeneous material is one that cannot be mechanically separated into different materials (e.g., plastic, metal coating, rubber, etc.).