EU REACH chemical testing process for rubber products
Date：2025-08-22 10:10:18 Classification
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SVHC testing refers to the testing for the content of substances controlled by SVHC under the REACH regulation. Rubber products exported to the EU must comply with the REACH chemical testing process and key requirements:
I. Pre-Test Preparation
1. Applicable Product Scope
- All rubber products containing chemical substances (such as NBR, EPDM, silicone seals, tires, protective gloves, etc.).
- Special Categories:
- Rubber products containing electronic components (such as conductive rubber and sensor hoses) must additionally comply with the RoHS Directive;
- Food contact products (such as pacifiers and food seals) must comply with EU Directive 1935/2004.
2. Material Pre-Qualification
- Collect chemical safety data sheets (SDS) from suppliers, prioritizing REACH-certified raw materials.
- Prepare a product bill of materials (BOM), clearly identifying all components and their content.
II. Core Testing Process
Step 1: SVHC Screening (Key Points)
- Test Substances: EU REACH SVHC List (250 items as of 2025, including newly added PAHs and plasticizers).
- Test Methods:
- Chemical Analysis (e.g., GC-MS for PAHs, HPLC/MS for plasticizers);
- Material Group Testing (Rubber is a non-metallic material requiring 209 tests).
- Limit Requirements: A single SVHC content > 0.1% triggers a reporting obligation.
Step 2: Compliance Testing
- Basic Items:
- Physical Properties (density, melting point, viscosity);
- Ecotoxicology (biodegradability, environmental persistence).
- Special Items:
- Adhesives: Additional curing and peel strength tests are required.
- Automotive Rubber Parts: Specialized Testing for PAHs and Hexavalent Chromium.
III. Notification and Certification
1. Notification Requirements
- If the total amount of SVHC in a product exceeds 0.1% and the annual export volume is ≥1 ton, notification to ECHA is required.
2. SCIP Database Submission
- All products containing SVHCs greater than 0.1% must submit chemical substance information to the EU SCIP database.
3. Report Obtaining
- Testing Turnaround: Typically 5-7 working days;
- Output: REACH test report (not a certificate).
IV. Cost and Time Optimization
- Fee Range:
- Non-metallic material testing is approximately 1,500 RMB per set (charged by material points);
- Notification fees are additional and depend on the substance type and tonnage.
- Cost-Saving Strategies:
- Mixed Group Testing: Combine samples of similar materials to reduce testing frequency;
- Pre-qualification Exemption: Use certified materials to reduce duplicate testing.
Key Notes
1. Dynamic Update: The SVHC list is updated every six months, and regular checks on the ECHA website are required.
2. Related Certifications:
- Electronic rubber components require additional RoHS testing (limited to 10 substances, including lead and cadmium);
- Protective rubber (such as industrial gloves) must comply with CE-PPE regulations.
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