Third-party heavy metals lab testing is mandatory for a wide range of products in the European Union, United States, Australia, and many other countries. In this guide, we explain what all importers must know about heavy metals testing costs, materials, limitations, risks, and how to handle failed test results.
Read these articles for an introduction to heavy metals regulations in the EU and the USA:
- Heavy Metals Regulations in the United States: An Overview
- Heavy Metals Regulations in the European Union: An Overview
What is heavy metals lab testing?
Heavy metals lab testing refers to the process of verifying if a certain material contains amounts of certain heavy metals – above the set limits. The specific heavy metals and the limits are specified in various regulations in the European Union, United States, Australia, and other countries.
Examples of heavy metals
Products and materials containing excessive amounts (e.g. above the limits) of certain heavy metals fail lab testing and are therefore non-compliant. Such products may be illegal to sell in certain countries.
Assuming the product or material passes the lab test, you’ll receive a test report that serves as evidence that your product or material is compliant. Having such test reports is mandatory for many products – children’s products and food contact materials in particular.
Which products and materials require heavy metals testing?
Heavy metals are restricted by several – sometimes overlapping – product regulations in the EU, US, and elsewhere. In the United States, CPSIA restricts heavy metals and other substances in children’s products. In the EU, heavy metals are regulated by REACH, RoHS, EU FCM Framework Regulation, and the Toy Safety Directive.
Examples of EU regulations
Examples of US regulations
- 21 CFR
- California Proposition 65
Product category examples
Heavy metals lab testing can therefore be applied to most consumer products, including:
- Children’s products
- Electronic components
- Food contact materials
- Packaging materials
- Paper and cardboard
Is heavy metals lab testing mandatory?
Yes, for many products third-party lab testing is mandatory. For example, you cannot sell children’s products in the United States that contain certain amounts of lead, cadmium, and other heavy metals. The US customs are even known to operate XRF scanners that can quickly check heavy metals in inbound product shipments.
In the EU, REACH restricts heavy metals in all consumer products.
Without a third-party lab test report, you cannot sell certain products in the EU and US.
Which heavy metals are regulated?
Heavy metals regulations and standards tend to cover lead, cadmium, mercury, arsenic, nickel, and many other heavy metals. To find out you’ll need to first identify which regulations apply to your product and materials.
How do I know the limits?
The limits depend on the applicable regulations and standards. Here are some examples:
ASTM F963-17 (USA)
- Antimony < 60 ppm
- Arsenic < 25 ppm
- Barium < 1000 ppm
- Cadmium < 75 ppm
- Chromium < 60 ppm
- Lead < 90 ppm
- Mercury < 60 ppm
- Selenium < 500 ppm
Plastic FCM: Regulation 10/2011
- Zinc: Not more than 100 mg/kg of plastic
- Copper: Not more than 5 mg/kg of plastic
- Lead: Not more than 2 mg/kg of plastic
- Arsenic: Not more than 1 mg/kg of plastic
- Chromium: Not more than 1 mg/kg of plastic
Note that the limits may be incorrect or outdated
My recommendation is that you ask a lab testing company to make this assessment for you. Intertek, QIMA, and other testing companies stay up to date with both the specific heavy metals to test for – and their respective limits.
Can we obtain a heavy metals lab test report from the supplier?
It is very rare to find manufacturers in China and elsewhere that can provide up-to-date and verifiable heavy metals lab test reports. There is simply not that much transparency in the material supply chain. As such it can be said that most manufacturers are unaware of the heavy metals content in their materials.
At best you’ll find suppliers that can provide outdated heavy metals test reports valid for a limited number of SKUs or materials. These reports are still useful, as it indicates that the supplier has some experience procuring ‘heavy metals compliant’ materials.
How much do heavy metals testing cost?
Heavy metals are generally included in testing protocols covering, for example, CPSIA and REACH. It is less common these days to only test for heavy metals as phthalates and other chemicals are also regulated.
Heavy metals testing often only makes up a fraction of the total testing cost, which can vary from a few hundred to several thousands of dollars.
California Proposition 65 Quotation Example
|California Prop 65 Total Cadmium (Cd) Content: Surface Coating||$20|
|California Prop 65 Total Cadmium (Cd) Content: Substrate||$40|
|California Prop 65 Total Lead (Pb) Content: Surface Coating||$20|
|California Prop 65 Total Lead (Pb) Content: Substrate||$55|
|California Prop 65 Phthalate Content (6P)||$310|
As you can see in the table above, phthalates testing makes up the bulk of the cost.
How can the testing cost be reduced?
Heavy metals lab testing costs are calculated based on the number of materials that require lab testing. The cost also depends on the type of material.
- Type of material (e.g. zinc alloy, dyed cotton fabric)
- Number of materials
- Number of colors
The more materials and color variations your product is made of, the more you’ll have to pay in heavy metals lab testing fees. Reducing the cost, therefore, requires that you limit the number of materials and colors.
What happens if the material fails testing?
A failed lab test demonstrates that your product is non-compliant and can most likely not be imported and sold. There is no way to “clean” heavy metals from a material. At best you can replace the specific components that contain excessive amounts of heavy metals.
How common are testing failures common due to heavy metals?
As explained by this report by SGS Hong Kong, excessive heavy metal content makes up a significant number of violations. Given that heavy metals can be found in paints and coatings it’s very hard to completely eliminate the risk.
What can happen if we don’t have a heavy metals test report?
As mentioned, third-party heavy metals lab testing is mandatory for many products. Failing to provide a lab test report can result in a recall, or issues with customs clearance.