Application Process for EU REACH Reports for Synthetic Leather Materials
Date：2026-11-10 09:33:38 Classification
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EU REACH Testing for Synthetic Leather
Testing Overview
Synthetic leather (including PU/PVC synthetic leather and microfiber leather) exported to the EU must comply with the REACH regulation (EC) No 1907/2006. For cross-border e-commerce and materials used in luggage, footwear, or furniture upholstery, compliance typically involves two approaches: screening for Substances of Very High Concern (SVHC) and testing for restricted substances listed under Annex XVII.
As synthetic leather features a multi-layered structure, it must be deconstructed into its individual components—such as the base fabric, foam layer, surface coating, printing ink, and adhesives—for separate testing.
Key Regulated Items:
- SVHC: Screening for substances included on the ECHA Candidate List.
- Annex XVII: Includes azo dyes, phthalates, heavy metals (cadmium, lead), organotin compounds, polycyclic aromatic hydrocarbons (PAHs), NP/NPEO, and short-chain chlorinated paraffins (SCCPs), among others.
For products intended for prolonged skin contact, testing for azo dyes and organotin compounds is mandatory and frequently required.
> Note: REACH "article" testing is distinct from REACH "substance" registration. Finished leather materials generally only require testing; formal ECHA registration is only triggered if the annual import volume of a raw material reaches or exceeds 1 metric ton. Required Documentation
1. Test application form, specifying the material type (PU/PVC/microfiber), intended use (bags/luggage, footwear, upholstery/sofas, or apparel), and whether it comes into contact with skin.
2. Material structure specifications: base fabric, foam layer, coating, adhesive, and printing process.
3. Bill of Materials (BOM) and a list of color codes (different colors require separate testing).
4. Samples: At least 20g per color; for multi-colored products, samples of every color must be provided.
5. Photographs of the product and a description of the manufacturing process.
Process
1. Submit documentation; an engineer will evaluate the structure, color, and intended use to determine the appropriate SVHC/Annex XVII testing plan and provide a quote.
2. Confirm the service request, sign the agreement, and complete payment.
3. Samples arrive at the laboratory; they are registered, photographed, and archived.
4. Samples are separated into layers and tested chemically according to the relevant standards.
5. If the product passes, an English-language REACH report (CNAS-accredited) is issued. If it fails, guidance on formulation and raw material adjustments is provided, followed by retesting once materials have been replaced.
6. Optional add-on: A REACH Declaration of Conformity, which can be used for Amazon product listings, client audits, or EU customs clearance inspections.
7. The report is valid only for the specific samples submitted for testing.
Turnaround Time and Notes
Standard turnaround time is 5–7 business days; expedited service (2–3 business days) is available.
Any changes to the material formulation, coating, adhesive, colorants, or production process necessitate retesting.
For PVC synthetic leather, there is a high risk regarding phthalates; for PU leather, the primary concerns are organotin compounds and azo dyes.
If products are also sold in the German market, clients often additionally request PAH (polycyclic aromatic hydrocarbon) testing.
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