Lead and cadmium EU REACH testing application process
Date：2025-11-27 10:22:15 Classification
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Lead and cadmium are heavy metals strictly controlled under the EU REACH regulation. Their testing process requires combining the limits specified in Annex 17 of REACH with the characteristics of the product materials to ensure compliance with EU market access standards.
I. Core Regulatory Basis: Lead and Cadmium Restrictions in Annex 17 of REACH
Annex 17 of the EU REACH regulation clearly restricts the use of lead (Pb) and cadmium (Cd), with significant differences in limits for different products:
- Lead:
- Lead content in toy materials ≤ 0.05% (500 ppm);
- Lead in electronic and electrical products ≤ 0.1% (1000 ppm);
- Lead release in jewelry ≤ 0.5 μg/cm²/week (for skin contact products).
- Cadmium:
- Cadmium content in all products ≤ 0.01% (100 ppm);
- Cadmium migration in children's products must comply with EN 71-3 standards (e.g., cadmium in toy materials ≤ 75 ppm).
II. Lead/Cadmium REACH Testing Procedure: 5 Standardized Steps
1. Determine Product Type and Testing Standards
- Select standards based on product material:
- Metals (e.g., jewelry, hardware accessories): Test for total lead/cadmium content (EN 1122:2001 standard);
- Plastics/Textiles (e.g., toys, clothing): Test for migratable lead/cadmium (EN 71-3:2019 standard, simulating gastric acid extraction);
- Electronic components (e.g., circuit boards): Test for lead/cadmium in homogeneous materials (IEC 62321 standard).
- Key Action: Provide the testing organization with a product BOM (Bill of Materials), specifying the material (e.g., "zinc alloy jewelry," "PVC plastic toys") to avoid missed or incorrect testing.
2. Choose an EU-accredited testing organization
⚠️ Qualification Requirements: The laboratory must be ISO 17025 certified.
- Avoid pitfalls: Be wary of organizations offering "fast reports." Lead and cadmium testing requires precise analysis using ICP-MS (Inductively Coupled Plasma Mass Spectrometry), with a standard turnaround time of ≥3 working days.
3. Sample Preparation and Submission
- Sample Quantity:
- Solid products: Provide 2-3 complete samples (e.g., jewelry must include all components such as chains and pendants);
- Liquids/Powders: 50-100g (sealed packaging, batch number indicated).
- Sample Requirements:
- Must represent "homogeneous materials" (e.g., plastic casings must be tested separately and cannot be mixed with metal parts);
- If the product contains multiple materials (e.g., "plastic handle + metal base"), it must be tested separately, and results must be provided for each.
4. Testing Process and Items
The laboratory performs the testing according to the following steps (taking toy plastic as an example):
1. Sample Pretreatment: Crush the plastic into particles ≤1mm and extract with 0.07mol/L hydrochloric acid (simulating gastric acid) at 37℃ for 2 hours;
2. Instrumental Analysis: Determine the concentration of lead (Pb) and cadmium (Cd) in the extract using ICP-MS;
3. Result Interpretation: Compare with the limits in REACH Annex 17 (e.g., cadmium ≤100ppm, lead ≤500ppm).
- Common Issues: For metal coatings (such as chrome-plated jewelry), additional testing of the coating thickness is required to avoid lead and cadmium release from the substrate due to coating peeling.
5. Report Issuance and Platform Review
- Key Report Information:
- Product Name, Model, Batch Number;
- Testing Standard (e.g., "EN 71-3:2019", "REACH Annex XVII");
- Test Results for Each Substance (must clearly state "Compliance Limit" or specific numerical value);
- Laboratory CNAS/CMA accreditation mark and signature/stamp.
- Platform Submission:
- Amazon EU: Upload the report PDF in "Compliance Documents," which must include "Contact Information of the Testing Institution" (the platform may verify by phone);
- Independent Website/Offline Trade: Provide the original report to the purchaser, and attach a "Declaration of Conformity" (DoC) if necessary.
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