EU REACH Chemical Testing Procedures for PVC Particles
Date：2025-12-30 09:41:48 Classification
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PVC, as a commonly used plastic raw material, has its chemical substance control directly affecting the compliance of products exported to the EU. Understanding the process can help you complete the testing efficiently and avoid delays in market access.
I. REACH Chemical Testing Process for PVC Granules in the EU
1. Clarify Testing Objectives and Regulatory Requirements
(1) Core Testing Scope
PVC granules are chemical formulations and must meet two core requirements of the REACH regulation:
SVHCs (Substances of Very High Concern): Testing for the latest 191 SVHCs, with each substance content ≤0.1% (by weight);
Appendix XVII (Restricted Substances): Focusing on phthalates (DEHP/DBP/BBP, etc.), lead, cadmium, polycyclic aromatic hydrocarbons, etc.
(2) Supplementary Testing for Special Scenarios
If used in food contact (e.g., packaging materials): Additional compliance with EU 10/2011 standards is required;
If used in toys: Phthalate restrictions in ASTM F963 or EN 71 standards must be met simultaneously.
2. Sample and Documentation Preparation
(1) Sample Requirements
Quantity: 500g (granular, must be thoroughly mixed to represent the batch);
State: Unused raw granules, avoid contamination or modification (if stabilizers have been added, please specify);
Packaging: Sealed bag or aluminum foil bag, labeled with batch number, production date, and ingredient description (if plasticizer type is included).
(2) Required Documents
| Document Type | Specific Content
| Product Information | PVC Particle Type, Hardness (e.g., 60/80 degrees), Application (e.g., Toys/Pipes/Electronic Components)
| Composition Declaration | Raw Material CAS Number (e.g., PVC Resin CAS 9002-86-2), Additive List (Plasticizers/Stabilizers)
| Company Information | Manufacturer Name, Address, Contact Information (EU importer information to be supplemented if notification is required)
3. Selecting a Compliant Testing Institution
(1) Qualification Requirements
Must be a third-party laboratory accredited by CNAS and registered with ECHA (e.g., Dezewei Testing CNAS Registration No.: L8083);
Must possess PVC-specific testing capabilities (e.g., GC-MS for plasticizer testing, ICP-MS for heavy metal testing).
4. Core Test Items and Methods
The following items should be emphasized in the REACH test for PVC granules (adjusted according to application):
(1) Mandatory Test Items (All PVC Granules)
| Test Item | Testing Standard/Method | Limit Requirements
| SVHC 191-item screening | EN 12393 (GC-MS/ICP-MS) | Single substance ≤0.1%
| Phthalate (6 types) | ISO 18856 (GC-MS) | DEHP+DBP+BBP total ≤0.1%
| Heavy Metals (Lead/Cadmium/Mercury) | EPA 3052 (ICP-MS) | Lead ≤1000mg/kg, Cadmium ≤100mg/kg
(2) Optional Test Items (Select as needed)
Total Plasticizer: Applicable to soft PVC (e.g., toys, medical supplies);
Chlorine Content: Verifies PVC purity (ASTM) D4327);
Heat stabilizers: Detection of lead salts/organotin compounds (such as DBT and DOT, which are banned in the EU);
Polycyclic aromatic hydrocarbons (PAHs): For products that come into contact with skin (such as fitness equipment).
5. Testing Process and Cycle
1. Sample Receipt and Confirmation (1 working day): The laboratory verifies the sample condition and data completeness;
2. Pretreatment (2-3 working days):
Solid particle crushing → Solvent extraction (for organic substances such as phthalates);
Microwave digestion (for heavy metal detection);
3. Instrumental Analysis (3-5 working days):
GC-MS analysis of organic matter (plasticizers, SVHCs);
ICP-MS analysis of heavy metal elements;
4. Report Preparation and Review (1-2 working days): Issuance of an English test report, including test results and conformity assessment.
Total Cycle: Regular 5-7 working days, expedited 3-5 working days (+50% fee).
6. Report Application and Subsequent Compliance
(1) Key Report Content
The report must include the laboratory's CNAS identification, testing standards (e.g., REACH Regulation (EC) 1907/2006), sample information, and test results (numerical values + limit comparison);
If used on platforms such as Amazon, it must additionally state "SVHC testing meets the 0.1% requirement."
(2) Subsequent Obligations
Notification Obligation: If the SVHC content is >0.1% and the annual export volume is >1 ton, a notification must be submitted to ECHA through the EU importer;
Supply Chain Transmission: Provide the REACH report to downstream customers to ensure the compliance of the entire product;
Update Requirements: The SVHC list is updated annually (an average of 10-20 new items are added), and it is recommended to retest annually.
II. Common Industry Misconceptions and Risk Warnings
1. "Only SVHC testing is sufficient": Incorrect! 1. If PVC granules contain phthalates, they must be tested separately for Annex XVII restrictions (even if SVHCs are not exceeded);
2. "Samples can be sent arbitrarily": Granules must be thoroughly mixed to avoid inaccurate results from sending only surface samples;
3. "Reports are valid indefinitely": After the SVHC list is updated, old reports may become invalid, requiring retesting for newly added substances.
Additional Notes for Exporting to the EU
If the PVC granules are used to produce toys: EN 71-3 (migration of specific elements) and EN 71-11 (organic compounds) must be met simultaneously;
If it is "recycled PVC": A declaration of origin for the raw materials is required, proving that it does not contain hazardous waste;
EU Customs Inspection: The original REACH report must be carried. Some ports require proof of the testing institution's accreditation.
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