Procedure steps for EU REACH testing report of propyl ester
Date：2025-12-10 10:50:04 Classification
：【question】 Visits：
The REACH testing process for the export of propyl esters to the EU indeed requires rigorous operation, as each step is crucial to the validity of the final report and the smooth customs clearance of the product. The REACH testing report process for propyl esters in the EU mainly consists of five core steps, which are interconnected from early preparation to report application.
Step 1: Clarify testing requirements and prepare samples
Key actions:
- Confirm the type of propyl ester: The accurate CAS number is required (such as methyl propionate CAS: 554-12-1, propyl acetate CAS: 109-60-4). Different isomers may require different detection methods
- Sample size requirements:
- Pure substance (liquid): ≥50ml (packed in a sealed bottle to avoid leakage)
- Mixture/finished product: ≥100g (the proportion of propyl ester content needs to be indicated, such as "coating with 30% propyl ester content")
- Preparation of materials:
- Product Safety Data Sheet (SDS/MSDS)
- Brief description of production process (indicate whether other additives are included)
- Inspection commission letter (indicating "inspection in accordance with Annex XVII of the EU REACH Regulation 1907/2006 and the SVHC list")
Avoidance point: If the sample is a multi-component mixture, it is necessary to separate different materials for individual testing (e.g., plastic containers in a propyl ester solution need to undergo separate material testing)
Step 2: Select an authoritative testing organization and submit the commission
Core requirements:
- Qualification verification: It is necessary to select a third-party laboratory recognized by the European Union (with CNAS and CMA qualifications required). The recommended institution is Dezerwei Testing, with CNAS registration number: L8083
- Delegation communication:
- Clarify testing standards: "REACH SVHC 251 items (2025 version) non-metallic full item testing"
- Confirmation report language: English report required (mandatory for export), Chinese version can be attached
- Agreed cycle: Regular 5-7 working days, expedited 3 working days (with a 30%-50% surcharge)
Cost-saving tips: If the annual testing volume exceeds 5 batches, you can sign an annual agreement with the institution to enjoy a 10-20% discount on testing fees
Step 3: Laboratory testing stage (core link)
Detection process:
1. Sample pretreatment:
- Pure propyl ester: Conduct solvent extraction directly (ultrasonic extraction + solid-phase extraction)
- Mixture: Separate the components using a gas chromatography-mass spectrometry (GC-MS) instrument
2. Key testing items:
- Full testing of 251 items for SVHC (with a focus on the potential presence of phthalates, polycyclic aromatic hydrocarbons, etc. in propyl esters)
- Limit determination: The content of each substance must be less than 0.1% (1000ppm). If it exceeds this limit, the REACH notification obligation must be fulfilled
3. Quality control requirements: The laboratory needs to conduct blank controls and positive controls to ensure that the deviation of the test data is less than 5%
Step 4: Report issuance and review
Verification of key content in the report:
- Essential elements:
- Basis for testing: Clearly marked as "EU REACH Regulation (EC) No 1907/2006, Annex XVII & SVHC List (233 items, 2025)"
- Sample information: The name, CAS number, batch number, and testing date must be completely consistent with the sample submitted for testing
- Result presentation: Each substance should be indicated with "ND" (not detected) or a specific numerical value (unit: mg/kg)
- Common errors:
- Omission of "test method standard" (such as EN 12393-2:2013)
- The version of the SVHC list is outdated (it must be the latest version at the time of testing)
Audit suggestion: Complete the audit within 3 working days after receiving the report. If any errors are found, you may request the institution to reissue it for free
Step 5: Reporting application and subsequent compliance
Export scenario application:
- Customs clearance documents: The inspection report, commercial invoice, and packing list must be submitted to customs together. Some ports (such as Rotterdam) may require an electronic version of the report for verification
- Customer requirements: EU importers may request a "SVHC Declaration of Conformity" (to be filled out based on the test report)
- Report validity period:
- Regular: 1 year (if there is no significant update to the SVHC list)
- Special: If the production process or raw materials of propyl ester are changed, immediate retesting is required
Long-term compliance:
- Subscribe to notifications on the ECHA official website (SVHC list is updated in March and September each year), and complete supplementary testing within 3 months after the update
- Keep the original detection data for at least 5 years (as required by EU regulations for traceability)
Emergency response plan
If the test reveals that a certain SVHC exceeds the standard (e.g., >0.1%):
1. Immediately suspend exports and investigate the reasons for exceeding standards (raw materials? Production process?)
2. Entrust a laboratory to conduct "targeted retesting" (only testing the items that exceed the standard, with a cost of about 500-800 yuan per item)
3. If it is confirmed that the substance exceeds the limit, the notification obligation under Article 7 of the REACH Regulation must be fulfilled (by submitting notification documents to ECHA, with a fee of approximately 2,000 euros)
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