Short-chain chlorinated paraffins EU REACH chemical testing
Date：2025-12-01 10:29:02 Classification
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Short-chain chlorinated paraffins (SCCPs) are strictly controlled hazardous substances under the EU REACH regulation, and their detection is a key hurdle for products exported to the EU. According to the latest regulations, all articles containing SCCPs must meet stringent limit standards and are completely prohibited.
I. Core Control Requirements of Short-Chain Chlorinated Paraffins (SCCPs) under the REACH Regulation
1. Regulatory Status and Limit Standards
- Dual Control: SCCPs are simultaneously listed in the REACH SVHC (Substances of Very High Concern) list and the EU POPs (Persistent Organic Pollutants) directive, with control requirements escalating accordingly:
- REACH SVHC: When the SCCP content in an article is >0.1% (1000 ppm), notification to the European Chemicals Agency (ECHA) is required, along with communication of safety information to downstream users.
- POPs Directive (EU 2019/1021): Since January 2013, the intentional addition of SCCPs to all articles is completely prohibited, and the residual amount of the impurity must not exceed 0.1% (1000 ppm), regardless of the intended use.
- Key Definition: SCCP refers to chlorinated paraffins with a carbon chain length of C10-C13. These compounds are highly bioaccumulative and toxic, capable of long-distance migration through air and water, and can cause irreversible damage to the reproductive and immune systems.
2. Applicable Products and Typical Application Scenarios
SCCP, due to its flame-retardant and plasticizing functions, is widely present in the following products and requires mandatory testing:
| Product Category | Common Application Scenarios
| Plastics and Rubber Products | PVC cables, plastic toys, rubber seals, artificial leather (as a flame retardant or plasticizer)
| Textiles and Leather | Fire-retardant fabrics (such as curtains, protective clothing), leather treatment agents (improving abrasion resistance)
| Metalworking Fluids | Cutting oils, lubricants (improving lubrication performance and oxidation resistance)
| Coatings and Adhesives | Industrial coatings, sealants (enhancing corrosion resistance and flexibility)
II. Core Testing Items and Methods
1. Mandatory Testing Items
- Total SCCP Test: Must cover all C10-C13 chlorinated paraffin homologues, including:
- Carbon chain distribution (C10, C11, C12, C13)
- Chlorine content (typically 40%-70%)
- Limit Requirements: ≤0.1% (1000ppm), and intentional addition is prohibited (even if below the limit, intentional use is still a violation).
2. Standard Detection Methods
- Gas Chromatography-Mass Spectrometry (GC-MS): Based on EN ISO 18219-1:2019, applicable to matrices such as plastics, rubber, and textiles.
- Sample Pretreatment: The matrix must be separated by methods such as Soxhlet extraction and solid-phase extraction (SPE) to ensure detection accuracy (detection limit up to 10ppm).
- Precautions: Medium-chain chlorinated paraffins (MCCP, C14-C17) may interfere with detection; selective ion scanning (SIM) mode must be used for differentiation.
III. Entire Testing and Certification Process
1. Testing Preparation
- Sample Requirements:
- Provide representative samples (e.g., slices for plastics, shredded for textiles), quantity ≥50g (or complete parts depending on product size).
- Submit a Bill of Materials (BOM) specifying any raw materials that may contain SCCP (e.g., flame retardant masterbatches, lubricant types).
- Institution Selection: The laboratory must be CNAS accredited and possess REACH testing qualifications (e.g., Dezeway Testing CNAS registration number: L8083). The report must include a declaration of compliance with POPs regulations.
2. Testing Process and Cycle
1. Pre-screening: Rapid qualitative analysis for SCCP presence (1-2 working days) to avoid wasting full testing costs.
2. Quantitative testing: Precise content determination of positive samples (3-5 working days), issuing a detailed test report (including homologue distribution maps).
3. Compliance assessment: If the result is ≤0.1%, it can be determined that it complies with REACH and POPs regulations; exceeding the limit requires raw material traceability and process rectification.
3. Core Elements of the Report
- Laboratory Qualifications (CNAS, CMA Marks)
- Testing Method Standards (e.g., EN ISO 18219-1)
- Sample Description and Pretreatment Process
- Specific Content and Total Amount of Each Carbon Chain Component (C10-C13)
- Comparison Conclusion with Regulatory Limits
IV. Corporate Compliance Risks and Countermeasures
1. High-Frequency Violation Scenarios
- Raw Material Contamination Risk: Recycled plastics and recycled rubber may contain SCCP residues (e.g., recycled cable materials).
- Process Contamination: Using old lubricating oil containing SCCP in metal processing equipment can lead to cross-contamination of products.
- Missing Labels: Failure to declare "SCCP content < 0.1%" in product instructions violates REACH information transmission requirements.
2. Practical Avoidance Guidelines
- Supply Chain Management:
- Require suppliers to provide SCCP testing reports for raw materials (focusing on flame retardants and lubricants), and prohibit the use of recycled materials.
- Sign compliance agreements specifying that SCCP in raw materials must not exceed 500 ppm (with a safety margin).
- Alternative solutions:
- Flame retardants: Use phosphate esters (such as TPP) or inorganic flame retardants (magnesium hydroxide).
- Plasticizers: Use citrate esters (ATBC) as a substitute, complying with EU environmental requirements.
- Regulatory monitoring: In 2025, the EU plans to extend SCCP control to medium-chain chlorinated paraffins (MCCP, C14-C17), requiring advance planning for testing capabilities.
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