Bracelet EU REACH testing process
Date：2025-10-28 10:14:38 Classification
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REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is the EU's chemical regulation aimed at protecting human health and the environment. Bracelets, as jewelry intended for skin contact, may contain restricted substances (such as heavy metals like lead and cadmium, or phthalates). Therefore, they must undergo REACH compliance testing before being exported to the EU market.
The Complete EU REACH Testing Process for Bracelets (5 Core Steps)
The process is essentially a "compliance assessment," not a single test, and involves material analysis, testing, and document preparation:
1. Preliminary Preparation and Needs Analysis
- Core Task: Determine the bracelet's composition and materials list (e.g., metal chain, leather cord, plastic jewelry beads, etc.), and compare them to REACH Annex XVII (Restricted Substances List) and SVHC (Substances of Very High Concern List).
- Key Actions:
- Collect supply chain documentation (e.g., MSDS and Chemical Safety Data Sheets from raw material suppliers).
- Identify potential risk substances (e.g., potential lead or mercury in the bracelet coating).
- Additional Tips: It's recommended to use online tools (such as the ECHA official database) to self-check substance limits (e.g., the lead limit is 0.05%). This is cost-effective and can save on subsequent testing costs.
2. Sample Submission and Laboratory Testing
- Core Task: Select an EU-approved laboratory (such as Dezeway) and submit samples for chemical testing.
- Key Operations:
- Provide representative samples (e.g., 3-5 bracelet components of different colors).
- Testing items include: heavy metal leachability testing (EN 71-3 standard) and SVHC screening.
- Additional Tips: The test report must comply with ISO 17025 standards; the average fee is 1,000-2,000 RMB (lower for simple metal bracelets, higher for complex mixed materials).
3. Report Review and Compliance Documentation Preparation
- Core Task: Obtain laboratory test reports and convert them into compliance documents.
- Key Operations:
- Evaluate the report results (if all substances are below the limits, the result is acceptable).
- Draft an EC Declaration of Conformity (DoC), including company information, product description, test standards, and a Declaration of Compliance.
- Additional Note: The DoC must be signed by the CEO or authorized person; if it fails to meet the requirements, materials must be modified or retested (adding an additional 1-2 weeks to the rework period).
4. Market Access and Labeling
- Core Task: Ensure that the product meets labeling requirements when placed on the EU market.
- Key Actions:
- Add the CE mark to product packaging or instructions (optional, but highly recommended).
- Prepare technical documentation (including test reports, DoC, and design drawings), and keep them for at least 10 years for random inspections.
- Additional Note: EU customs will conduct random inspections; if approved, no additional registration is required (REACH registration is primarily for the chemical itself; the finished bracelet will primarily require a Declaration of Compliance).
5. Subsequent Monitoring and Ongoing Compliance
- Core Task: Establish a response mechanism to address regulatory updates (e.g., the annual addition of new substances to the SVHC list).
- Key Actions:
- Subscribe to ECHA announcements (e.g., five new substances added to the SVHC list in 2025).
- Regular retests (recommended every 1-2 years or when materials change).
Notes and Optimization Suggestions
- Time and Cost Optimization: Schedule appointments with the laboratory in advance (expedited scheduling during peak seasons, such as the end of the year). Discounts are available for batch testing; the total cost accounts for approximately 3-8% of the total export fee.
- Common Risks: Bracelets often fail due to excessive plating or dye content (e.g., excessive cadmium). Be sure to request a certificate of compliance from the supplier.
- Regulatory Dependencies: While REACH and RoHS (Waste and Electronics Directive) are different, metal jewelry may require dual testing (RoHS targets electronic components).
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