• REACH Product Lab Testing: A Complete Guide

    Posted on 21 Comments

    The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation sets bans, limitations, and notification requirements for chemicals, heavy metals, and other harmful substances. The regulation covers consumer products imported to or manufactured in the European Union.

    REACH lab testing is necessary in order to determine whether a product or material is compliant. In this guide, we explain what importers and manufacturers must know about the testing process, why testing is important, cost examples, and more.

    What is REACH testing?

    REACH lab testing is the process of verifying if a certain material contains restricted or banned chemicals, heavy metals, or other substances. The lab test is only passed if not a single restricted or banned substance is above the limits.

    Substance examples

    Notice that substances listed in Annex XVII are banned or limited. Further, additional testing for Substances of Very High Concern (SVHC) is also often necessary.

    You’ll receive a lab test report once the testing process is completed. This document can serve as proof of compliance – assuming the product passes the lab test.

    REACH lab testing

    Is REACH lab testing required?

    Yes, REACH lab testing is necessary for the sake of verifying compliance with the REACH regulation. Without a lab test report, there is no way to know if a certain material contains banned or restricted substances.

    Do we need SVHC testing?

    Substances of Very High Concern (SVHC) are chemicals or other substances that are not necessarily banned. However, importers and manufacturers in the EU are still required to keep track of SVHCs – for the following two reasons:

    a. Consumers have the right to request information about SVHC content above 0.1% by weight in a product

    b. Companies must submit a notification to the European Chemicals Agency (ECHA) if a product contains any SVHC above 0.1% by weight

    Hence, SVHC lab testing is necessary for the following reasons:

    • Provide consumers with SVHC data upon request
    • Submit SVHC data to the ECHA when/if you exceed the quantity threshold

    How often do we need to submit our products for REACH testing?

    It’s important to stay up to date with the REACH regulation as new substances are added to Annex XVII or the list of SVHCs. As such, last year’s REACH test report may already be outdated.

    Further, one batch of materials could also be compliant while the next is not. Materials can be contaminated during production (e.g. infused with a restricted substance), which is why periodic testing is necessary. That said, I cannot give an exact estimate as to the frequency of testing you should expect.

    What products can be REACH lab tested?

    As REACH is applicable to all consumer products sold in the European Union, essentially all products and materials can be subject to REACH lab testing.

    Therefore, REACH lab testing is applicable to the following products:

    • Textiles
    • Plastic products
    • Jewelry and accessories
    • Watches
    • Furniture

    Materials

    Likewise, REACH lab testing can be applied to essentially all materials:

    • Plastics
    • Stainless steel
    • Metal alloys
    • Glassware
    • Coatings and paints
    • Leather
    • Textiles
    • Ceramics

    REACH lab testing costs

    REACH testing costs are multiplied based on the number of materials and colors. As such, a single colored material sample test costs less than a product made of multiple materials and color variations.

    How much does REACH lab testing cost?

    REACH lab testing can cost from 100 USD and up, depending on the number of materials, colors, and applicable substance tests. Further, additional costs apply if you also wish to test SVHCs in addition to Annex XVII substances.

    Example A: Red T-Shirt

    A single-colored material test is less expensive, as detailed in the table below.

    Overview # Tests Cost (USD)
    REACH-Nickel Release 1 70
    REACH-Total Cadmium Content 1 20
    REACH-Phthalate Content 1 40
    REACH-Organotin Content 1 100
    REACH-Pentachlorophenol Content 1 90
    Total cost (US Dollars) 320

    Example B: Wrist Watch

    However, a wristwatch made up of a watch case and leather strap costs more to test:

    Overview # Tests Cost (USD)
    REACH-Nickel Release 2 70
    REACH-Total Cadmium Content 2 20
    REACH-Phthalate Content 2 40
    REACH-Organotin Content 2 100
    REACH-Pentachlorophenol Content 2 90
    REACH-Hexavalent Chromium Content in Leather 1 50
    REACH-Azo Colorants Content in Leather 1 50
    Total cost (US Dollars) 740

    How do I know which chemicals and heavy metals to check?

    Our recommendation is that you contact a qualified lab testing company to help you determine which Annex XVII and SVHC tests apply to your specific product and material. The specific list varies, depending on the product type and material. Further, new substances are added to both Annex XVII and the list of SVHCs from time to time.

    Third-party lab testing companies, such as Intertek and QIMA, must assess applicable REACH tests when providing a quotation. This is often done free of charge and can be very helpful when trying to determine which substance tests apply to your products.

    Another option is to work with a REACH consultant.

    What should we do if the REACH test fails?

    Failed REACH testing means that the material contains one or more restricted or banned substances – above the limits. There is no way to ‘repair’ or otherwise make a non-compliant material become compliant. At best you can ask your supplier to replace the non-compliant material, assuming that is possible without destroying the product.

    REACH testing failure is always a risk, especially when importing from outside the EU where REACH compliance is not the default. A few years ago we had a situation in which a customer booked shipping before the REACH test result came through.

    That proved to be a disaster as the plastic material used to make their product turned out to be contaminated by machine lubrication – which resulted in excessive amounts of restricted phthalates. It’s also worth noting that the supplier had passed all REACH tests for all previous production runs – but an accident can happen even with the best intentions.

    Hence, ensure that you arrange REACH testing before you pay your supplier and book shipping.

    Can I get a test report from my supplier?

    Many importers assume that every single supplier in the world can provide a REACH test report for every single product and material. This is very rarely the case. It’s actually quite rare to find that suppliers can provide REACH lab test reports for more than a few materials – and the test reports are often outdated.

    It’s therefore not a viable option to rely on existing lab test reports. This is also why third-party REACH lab testing is so often a necessity when importing products from China, and other countries outside the EU.

    That being said, you can still use “outdated” REACH test reports as a way to assess if the supplier has experience in the past manufacturing REACH compliant products and materials.

    Can REACH lab testing only be done within the EU?

    No, there are many lab testing companies conducting lab tests according to the REACH regulation in China, the United States, and many other countries.

    How do I submit products or materials samples for testing?

    You can either instruct your factory to deliver samples directly to the testing company or send them yourself. You will normally be instructed by the testing company to send the samples to a designated lab address, and write the booking number in order to help the lab identify your samples upon arrival.

    How long does REACH testing take?

    The processing time from submission until you receive the lab test report is normally somewhere between 7 to 21 days. This varies between labs and the product you submit for testing.

    Do all EU importers get their products REACH tested?

    The short answer is no. Many importers are not aware of the REACH Regulation or understand how to verify compliance means in practice.

    Further, many importers make the faulty assumption that their suppliers got them covered and that it’s the supplier’s responsibility to ensure compliance with the REACH regulation.

    Who checks REACH lab test reports?

    National market surveillance authorities in the European Union carry out on-site inspections and request test reports from e-commerce companies.

    Does Amazon require REACH lab test reports?

    Amazon may also check your test reports if you sell products on their marketplace. From 2020 and on we started receiving reports from sellers that had their products removed as a result of failing to provide REACH lab test reports to Amazon.

    This is also one reason why you should get your products REACH tested before importing products to the EU.

    REACH Test Report Sample

    REACH test report sample

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    Disclaimer: The content on this website is provided for general information only. The content includes summaries written by our team members based on publicly available information about product safety standards, labeling, documentation, testing, processes, and other product compliance related topics. However, we don’t guarantee that we cover every single relevant regulation/standard/requirement, or that the information is free from errors, or covering every single scenario and exemption. We do make mistakes from time to time. We never provide legal advice of any sort.

    Changes/Updates: Product standards and substance restrictions are subject to frequent updates and changes. In addition, new regulations, standards, and/or requirements may also become effective at any time. We don’t update our articles whenever new standards/regulations/rules are added or changed. We recommend that you consult a lab testing company or other professional to get the latest information about mandatory standards/regulations in your market, country, or state. Lab testing companies generally stay up to date on new and updated standards and regulations.

    National/State-Level Standards/Regulations: Many articles don't cover all European national and US state standards, regulations, and requirements. We recommend that you consult a testing company or other professional to confirm all relevant (and current) national/state level standards and regulations.
  • 21 Responses to “REACH Product Lab Testing: A Complete Guide

    1. Gavin at 6:21 am

      Hi Fredrik,

      Our company sells home decor mirrors (full length). Do you think we would need to do lab testing or have an Authorized Representative in order to enter the EU?

      Our belief is that we would not because it is not a high-touch product. Would love to know your thoughts.

      Best,
      Gavin

    2. Joseph Vino at 4:51 am

      I have a protein shake that I would like to have tested. There is a really bad after taste and after doing some research others have reported about the taste as well. I have been drinking these shakes for a while and this one batch seems to have the bad taste. I am trying to find out if there is something that might have gotten into the shake accidently. This is not my product. I just bought it retail. Is this something your lab could do?

      1. Fredrik Gronkvist at 2:13 pm

        Hi Joseph,

        It would cost you at least 400-600 USD to get it FCM tested.

        1. Contact the brand or seller and ask if they have a lab test report

        2. Stop using the shaker

    3. johan basson at 4:34 pm

      Good day Fredrik
      Hope you well.
      I have a customer who wants testing done in relation to lead content in brass products. Can you please advice me on who to contact?
      We are UK based and I’m finding it hard to find a relevant lab to do testing on the above.
      Thanks in advance
      Johan Basson

      1. Fredrik Gronkvist at 2:18 pm

        Hi Johan,

        You can try the companies listed here:

        https://www.compliancegate.com/reach-lab-testing-companies/

    4. lillian rodriguez at 8:32 am

      Regarding REACH (SVHC) products with different materials and parts, are we required to test all the parts even though parts are inside of the product? For example recumbent bike belt drive, or indoor cycling bike brake pads. Would it be acceptable to test the paint and main components?

      1. Fredrik Gronkvist at 11:41 am

        Hi Lillian,

        I asked this question a few months ago to the Swedish Chemical Agency but did not get a clear answer…

    5. Aidan at 8:13 pm

      Hello – I am trying to confirm what REACH Testing I need to provide for every product and what REACH testing I can do on a batch basis, every 6/12 months.

      For example, I will test a PU bag to the relevant REACH Annex XVII, for every bag but I will apply the REACH SVHC 211 for the PU used to make the bag once every 6 or 12 months.

      Do you think that is a reasonable compliance plan?

      Thanks,
      Aidan

    6. Emanuele at 6:11 pm

      Hello ,your blog is very beatiful .I have a question , if i want import different style of bracelets or pendant in EU , is necessary to test every model ? Is necessary make ,and pay,many REACH test for every model of my product ?I want import 500 diffrent style bracelets , is necessary make a test REACH for every model ?Thank

      1. Fredrik Gronkvist at 11:19 am

        Hello Emanuele,

        That depends. Are these different models made from the same material?

        1. Esther at 4:42 pm

          Hello

          if a manufacturer only works with one type of material i.e. stainless steel or sterling silver, would it be necessary to test all of their jewellery or would testing one rose gold , one gold plated and one silver jewellery be enough?

          Or would one have to test every single item purchased from the manufacturer?

    7. Rhys Tilbury at 11:54 am

      Hello, I work for a cosulting lab in Australia, with a client looking to sell their products in the UK/EU. Do we have to be a REACH certified lab to issue compliancy or can we provide a break down of the materials with regards to SVHCs ?

      Thank You.

    8. S.C. at 2:12 am

      Hi,
      I’ve been working with a supplier via Alibaba in China, on developing a custom *pet* shampoo product. They’ve sent me the samples with their test certifications, all clear. I’ve tried the sample myself (first!) and only then my personal pets. Results are great – even better than most supermarket brands I’d say. No allergic reactions, or noticeable issues.

      But I too am struggling with the “REACH” issue – as I want to sell via Amazon in the UK/ EU, I want to know whether it would be sufficient to have my supplier’s test certs, or do I still need to have a REACH test done via third party lab? Nobody is getting back to me, with lockdown, so I’m just basically waiting.

      Would appreciate a suggestion please – thanks! Great article too.

      1. Fredrik Gronkvist at 10:54 am

        I think this might go beyond REACH and into cosmetic product regulations. That’s outside my area of expertise though.

    9. Fabian at 9:26 pm

      If I am buying products from suppliers which are inside the European Union and I am selling those products through dropshipping also inside the European Union, would I be responsible for a REACH test if it was mandatory or would it be te manufacturer? Because as far as I know in the European Union the manufacturer is liable for the product and not the seller.

      1. Fredrik Gronkvist at 1:14 pm

        Hi Fabien,

        I think you are right

    10. shaily bhargava at 5:58 pm

      Dear Sir/ Mam,

      Can you guide me what are the test applicable on Textile and leather material as per reach. As i am working in lab and very new to REACH Testing.

      1. Fredrik Gronkvist at 7:20 pm

        Hello Shaily,

        If you are working in a product testing lab then you should have someone that stays up to date on new substance restrictions and limits. It’s up to the lab to decide which REACH SVHC tests to apply to a certain product and material.

    11. Find Lab Testing at 12:14 pm

      Your blog is helpful for us. It’s very informative. Thanks!

      1. Deepak Kumar at 2:58 pm

        For REACH testing, feel free to contact:
        TUV NORD
        [email protected]

        1. Fredrik Gronkvist at 1:13 pm

          Hi Deepak,

          Do you have any suggestions for our readers when it comes to REACH compliance testing?

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