EU REACHSVHC Testing and Certification Guide for Detergent Packaging
Date：2025-07-31 09:46:55 Classification
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This guide to REACH SVHC testing and certification required for detergent packaging exported to the EU combines EU regulatory requirements with the latest industry practices, covering core processes, key requirements, and risk mitigation strategies:
I. Which detergent packaging requires REACH SVHC testing?
According to REACH Regulation (EC 1907/2006), all packaging materials that come into direct contact with the detergent contents must be tested, including:
1. Plastic Packaging
- Bottles (PET, HDPE), spray nozzles, pump heads, caps, liner films, etc., require testing for plasticizer (phthalates) and bisphenol A migration.
2. Metal Packaging
- Aluminum cans, iron cans, and spray can valves require testing for heavy metal (lead, cadmium, nickel) leachability (limits: lead ≤ 0.05%, cadmium ≤ 0.01%).
3. Composite Material Packaging
- Hoses (aluminum-plastic composite) and multi-layer bags (paper-plastic composite) require testing of each material component separately.
4. Printing Inks and Adhesives
- Packaging label inks and sealing adhesives require testing for azo dyes and polycyclic aromatic hydrocarbons (PAHs).
> Exemptions: Outer boxes and bags that do not come into contact with cleaning agents do not require testing, but if there is a risk of indirect contact (e.g., liquid leakage), they must be evaluated.
II. Core Certification Process and Requirements
Step 1: Confirm Testing Scope and Standards
| Test Targets | Test Items
| Plastic Parts | Phthalates (6P), Nonylphenol
| Metal Parts | Lead, Cadmium, Nickel Extractables
| Printing Layer/Adhesive | Azo Dyes (≤30mg/kg), PAHs
| Special Requirements | Migratable Heavy Metals (Simulating Cleaner Immersion)
Step 2: Select a Compliant Laboratory
- The laboratory must be CPSC-authorized (e.g., ID 1552) and ISO/IEC 17025-accredited.
- Provide a packaging material declaration (e.g., PP content ≥ 95%) to reduce redundant testing.
Step 3: Sample Preparation and Testing
- Sample Requirements:
- Provide complete packaging components (bottle + cap + applicator) and individual material cutouts (3-5 pieces each).
- Mark areas of contact with the detergent (e.g., the inner wall of the bottle).
- Testing Turnaround: 5-7 working days for basic testing.
Step 4: Report and Certificate Preparation
- Test Report: Must include SVHC listed substance concentrations (accurate to the 0.1% threshold) and migration data.
- Declaration of Conformity (CoC): Signed by the manufacturer/importer, it must include:
① Product name and batch number
② Declaration of compliance with REACH Annex XVII and the SVHC list (up to 250 items)
③ Laboratory name and test number
④ Supply chain traceability information (manufacturer's address, importer's EU address)
III. High-Risk Substances and Common Failure Cases
| Issue Type | Typical Cases
| Plasticizer Exceeding Standard | DEHP Contained in PVC Pump Head > 0.1%
| Ink Contamination | Label Contains Banned Azo Dyes
| Migration Exceeding Standard | Nickel Release from Metal Cans > 0.2 μg/cm²/Week
| Incomplete Certificate Information | Missing Production Batch or Laboratory ID Number
IV. Cost and Timeframe References
| Packaging Type | Testing Fee
| Single Material (e.g., HDPE Bottle) | ¥800-¥1500
| Composite Material (Aluminum-Plastic Pipe) | Starting from ¥2,000
V. Key Compliance Management Points
1. Dynamic Monitoring:
- Quarterly review of the [ECHA official website SVHC list updates](https://echa.europa.eu/candidate-list-table), currently 250 items.
2. Supply Chain Traceability:
- Require raw material suppliers to provide REACH compliance declarations to prevent contamination at the source.
3. Amazon Compliance:
- Submit the CoC and complete report in the Seller Center. Product listings must be marked "REACH Compliant."
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