How to obtain a REACH report for metal accessories in the EU?
Date：2026-09-08 09:42:08 Classification
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Guidelines for REACH Reporting of Metal Accessories in the EU
I. Clarifying Product Scope and Applicable Regulations
When exporting metal accessories (such as buttons, zippers, chains, earrings, rings, bracelets, necklace pendants, belt buckles, badges, etc.) to the EU, the applicable REACH requirements must be determined based on the material composition:
Pure metal products: Focus on nickel release, lead, cadmium, and other heavy metals.
Metal + plastic/rubber/coating assemblies: SVHC assessment must be performed separately for each homogeneous material.
Welded/bonded components: Pay attention to restricted substances in additives and adhesives.
The key to REACH compliance is testing whether the content of substances in each homogeneous material exceeds the limits.
II. Processing Procedure (5 Steps)
Step 1: Selecting a Testing Institution
Choose a third-party laboratory with CNAS, CMA accreditation, or EU GLP certification (DEZEW Testing CNAS Registration No.: L8083).
Prioritize institutions with experience in testing metal accessories to improve efficiency.
Confirm whether the laboratory report is acceptable to EU customs and clients.
Step 2: Preparing Samples and Documents
The following information is required:
Product BOM (Bill of Materials): List each material (copper, stainless steel, zinc alloy, plating, etc.)
Sample Quantity: Prepare according to the type of product material, usually 5-10 pieces per main material.
Product Images and Usage Description: To help the laboratory determine the testing items.
Step 3: Determining Testing Items
Core testing items for metal accessories include:
| Test Item | Limit Requirements | Applicable Situations
| Nickel Release (EN 1811) | ≤0.5 μg/cm²/week | Metal parts in direct contact with skin
| Lead (Pb) | Varies by material type | General metals
| Cadmium (Cd) | ≤0.01% (plastics); ≤100ppm (metals) | Metal coatings, alloys
| SVHC screening | Single substance less than 0.1% (w/w) | All materials
| Appendix XVII Restricted Substances | As per substance regulations | Depends on specific materials
Important Note: If the product contains non-metallic parts such as plastics, rubber, and leather (e.g., leather belt buckles), additional testing for phthalates, azo dyes, etc., is required.
Step 4: Sample Submission for Testing
Testing cycle is generally 5-7 working days (routine items)
Testing methods are based on EU standards
Step 5: Report Issuance and Subsequent Use
Obtain an official REACH test report (English version or bilingual (English and Chinese))
The report can be used for: EU customs clearance, brand factory audits, compliance reviews on platforms such as Amazon
III. Key Considerations
1. Nickel release is of paramount importance for metal accessories: Long-term contact with nickel-containing jewelry can easily cause allergies ("jewelry dermatitis"), and EU enforcement is strict. 1. Nickel release testing is mandatory for metal parts that come into direct contact with skin.
2. Testing is conducted on a "homogeneous material" basis: For example, in a gold-plated ring, the metal substrate and plating are considered independent homogeneous materials, and their SVHC content must be assessed separately.
3. The SVHC list is continuously updated: The current candidate list exceeds 235 substances. Screening is recommended at least annually to avoid using newly added substances.
4. Report validity: Test reports themselves do not have a fixed validity period, but clients or platforms may require reports within one year.
5. CE marking: REACH itself does not require CE marking, but for some accessories intended for children, safety standards such as EN 71 must be considered.
IV. Cost Reference
Testing costs vary depending on the number of tests and sample complexity:
Basic three tests (lead, cadmium, nickel release): Approximately 1000-3000 RMB/item
The above prices are for reference only; actual prices will be quoted by the laboratory.
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