Detailed Procedure for Obtaining an EU REACH Test Report for Lithium-Based Greas
Date：2026-10-22 09:54:11 Classification
：【question】 Visits：
Detailed Procedure for Obtaining an EU REACH Test Report for Lithium-Based Grease
Lithium-based grease is classified as a chemical mixture and is subject to the EU REACH regulation (EC 1907/2006). Clients typically request screening for Substances of Very High Concern (SVHC); testing for restricted substances under Annex XVII can also be included. Such reports are often required for cross-border e-commerce platform audits, client documentation, and downstream compliance verification. The SVHC list is dynamically updated by the European Chemicals Agency (ECHA); the version current at the time of sample submission applies. The threshold for SVHCs is 0.1% (by weight).
I. Preliminary Confirmation and Preparation
1. Complete the test application form, specifying the product name, model, brand, applicant information, and desired report language. Select the appropriate testing package (e.g., SVHC screening and/or Annex XVII restricted substances).
2. Prepare supporting documentation: a brief product formulation, a Safety Data Sheet (SDS) if available, and photographs of the product label. Inform the laboratory of the specific type of lithium-based grease (e.g., general-purpose lithium grease vs. complex lithium grease) to assist in selecting the correct sample pre-treatment method.
3. Consult on the testing plan: Since lithium-based grease consists of a base oil, a lithium soap thickener, and various additives—which may contain substances like polycyclic aromatic hydrocarbons (PAHs) or short-chain chlorinated paraffins (SCCPs)—discuss whether additional targeted tests are required. Note that a REACH test report is not the same as REACH registration; registration is a formal submission to the ECHA required only if the volume exceeds 1 metric ton per year, whereas a test report serves as verification through substance screening.
II. Sample Submission Requirements
Submit at least 50 grams of the lithium-based grease in a sealed container to prevent contamination or leakage. Samples should be submitted in their original state; no dilution by the client is necessary. Upon receipt, the laboratory will retain the sample, perform homogenization and extraction/purification, and then proceed with instrumental analysis.
III. Laboratory Testing Phase
At DTi (Dezewei), the standard turnaround time is 5 to 7 business days, beginning once all samples and documentation have been received and the testing plan has been finalized.
Screening is conducted using instruments such as GC-MS, LC-MS, and ICP. If a target substance is detected, confirmatory testing is performed to determine whether its concentration exceeds the 0.1% threshold. If the sample matrix is complex or retesting is required, the turnaround time will be extended accordingly.
IV. Report Review, Issuance, and Handling of Results
1. Engineers will review the raw spectra and data, and compare them against the ECHA (European Chemicals Agency) candidate list to determine the results.
2. For compliant samples, a REACH test report—backed by CNAS accreditation—will be issued. This report is available in both Chinese and English and includes sample details, the list of substances tested, detected results, regulatory limits, and final conclusions.
3. If an SVHC (Substance of Very High Concern) is detected at a concentration exceeding 0.1%, the name and concentration of the substance will be provided. Clients may choose to replace raw materials or adjust their formulations and resubmit samples for retesting; such retesting will be charged separately.
4. Usage of the report: As lubricating grease is classified as a "mixture," exports to the EU must be accompanied by a compliant SDS (including CLP classification and labeling). The REACH test report serves as supporting documentation to be provided to importers or relevant platforms for review.
V. Important Notes
1. A REACH report is valid only for the specific sample submitted. Any subsequent changes to formulations, additives, or raw material suppliers will necessitate retesting.
2. Distinction between compliance obligations: SVHC testing alone does not constitute REACH registration. If the annual export volume of a single substance to the EU reaches or exceeds 1 metric ton, that substance must undergo REACH registration, which requires the appointment of an Only Representative (OR) based within the EU.
3. Additional regulatory considerations: For lithium-based lubricating grease exported to the EU, in addition to REACH requirements, a CLP classification and labeling assessment is necessary. If the product is used as a component within a finished good, downstream customers may also require verification of compliance with other regulations, such as those concerning POPs (Persistent Organic Pollutants).
4. If an SVHC is present at a concentration exceeding 0.1%, information must be communicated to downstream customers; in the case of mixtures, the SDS must be updated accordingly.
Shen Gongwang Security: 44030602006947