REACH (Registration, Evaluation, Authorisation, and restriction of CHemicals) regulates chemicals, heavy metals and pollutants in all consumer products imported to or manufactured in the European Union.
Third-party lab testing is the only way to verify that your product or REACH compliant, and therefore legal to sell in the European Union.
In this guide, we explain what every importer and exporter must know about REACH lab testing.
What is REACH testing?
REACH lab testing is essentially a material analysis measuring the chemicals and heavy metals content of restricted SVHCs (Substances of Very High Concern).
Once the test is done you’ll receive a REACH lab test report which can be used as proof of compliance – assuming the product passes the lab test.
The lab test can only pass if all regulated substances, such as lead and cadmium, are below the limits set by the REACH regulation.
What is an SVHC?
SVHCs are chemicals, heavy metals and pollutants banned or restricted by the EU. For example, the REACH regulation sets maximum limits on lead, cadmium, AZO dyes and hundreds of other substances.
What products can be REACH lab tested?
As REACH is applicable to all consumer goods 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:
- Plastic products
- Jewelry and accessories
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 is a REACH lab test?
The average lab test costs between $300 to $600, assuming you intend to test two to three different materials and color variations. However, this figure is only based on our customer average spend.
Example A: Red T-Shirt
A single-colored material test is less expensive, as detailed in the table below.
|Overview||# Tests||Cost (USD)|
|REACH-Total Cadmium Content||1||20|
|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-Total Cadmium Content||2||20|
|REACH-Hexavalent Chromium Content in Leather||1||50|
|REACH-Azo Colorants Content in Leather||1||50|
|Total cost (US Dollars)||740|
Is REACH third-party testing mandatory?
No, it’s not, and this is what also confuses a lot of importers, exporters, and manufacturers. All products sold in the EU must be REACH compliant, in the sense that products must not contain regulated substances above the legal limit.
Products containing substances, such as lead and mercury, above the legal limits, are illegal to import and sell in the European Union.
However, that being the case doesn’t mean that third-party REACH SVHC lab testing is mandatory. It’s up to you as an importer to decide whether you want your product to be REACH tested or not.
That said, the importer must ‘ensure’ that the product is REACH compliant. In practice, a third-party lab test is the only way to do so.
How do I know which chemicals and heavy metals to check?
The good thing is that you, as an importer or exporter, don’t have to know which chemicals and heavy metals to check. In other words, you don’t need to tell the testing company which substances to include in the lab test and the limits that apply.
The testing company makes that assessment for you, in the sense that they know what to look for based on the material.
For example, testing companies such as QIMA and Bureau Veritas have a list of chemicals and heavy metals for different types of textiles, alloys, and plastics.
All you need to do is to tell them that you want your products to be REACH tested.
Can I get a test report from my supplier?
In theory, yes. However, the situation is that manufacturers in China, and other exporting countries in Asia, don’t have test reports for every single material.
At best, they may have a few old REACH test reports valid for a limited range of products and materials used in the past.
But, it’s incredibly unlikely that you’ll find a supplier that can provide traceable test reports for the specific product or material you intend to import to the EU.
In an ideal scenario, all materials manufacturers in, for example, China would have test reports for all their materials and submit these to their customers, such as factories listed on Alibaba.com.
However, we are many years, if not decades, away from that being a reality.
Cost is obviously the main obstacle, as REACH lab testing is not exactly free. Further, few manufacturers have the expertise and equipment to do such tests on their own.
Do all EU importers get their products REACH tested?
Certainly not. The problem here is that national market surveillance authorities in the EU could do a better job when it comes to informing importers, exporters and manufacturers about what REACH actually are, and how they should ensure compliance.
Second, they could also do more when it comes to enforcement.
The truth is that most small businesses importing products to the EU don’t understand what REACH is all about. Much less what they must do to verify if their products are compliant.
I’ve even worked with purchasing managers, working for major retailers. responsible for tens of millions of Euros of orders, who struggle to get a grip around REACH compliance.
How does the EU enforce REACH lab testing?
Although relatively rare, national market surveillance authorities in the EU carry out on-site inspections and request test reports from e-commerce companies. This is also why you should get your products REACH tested before importing products to the EU.
That said, I believe that compliance enforcement will become stricter in the future.
Are products purchased from Aliexpress and Wish REACH tested?
Dropshippers and non-EU e-commerce sellers rarely, if ever, get their products REACH tested. This is simply because REACH is only applicable to EU companies. There is no way to enforce REACH in China, Vietnam or anywhere that’s not part of the European Union.
That said, a product can technically be REACH compliant without being tested.
List REACH lab testing companies
Here are some companies offering REACH compliance testing:
- Bureau Veritas