Detailed Explanation of the EU REACH Testing Procedure for Chemical Coatings
Date：2025-12-25 10:32:19 Classification
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After all, coatings are complex products involving numerous chemical substances. Understanding the testing process in advance helps companies better meet regulatory requirements and smoothly enter the EU market.
**Complete Guide to EU REACH Testing for Chemical Coatings**
Based on the latest regulatory requirements of 2025 and the characteristics of coating products, the following is a complete operational process from preparation to compliance:
1. Preliminary Assessment and Preparation Stage
Determine the Product Type
Distinguish whether the coating is a pure substance, a formulation, or an article (if the finished coating is a formulation, the compliance of each component in the formula needs to be considered).
Key Information Collection
Provide a complete formulation list (including pigments, resins, solvents, additives, etc.), specifying the CAS number and content of each component.
Determine the annual export volume (if the annual import volume as a substance/preparation is ≥1 ton, REACH registration is required).
Prepare a draft Product Safety Data Sheet (SDS) (if already available).
Select a Testing Institution
Prioritize laboratories with EU accreditation (e.g., ISO 17025), such as Dezeway Testing CNAS registration number: L8083.
2. Testing Application and Sample Submission
Complete the application form.
Include company information (name, address), sample name (e.g., "water-based acrylic coating"), testing standard (default is the latest ECHA SVHC list), and report language (Chinese-English bilingual or English).
Sample Requirements
Liquid Coatings: 50-100mL/sample (sealed in glass or plastic container to prevent solvent evaporation)
Powder Coatings: 20-50g/sample (please specify whether it contains metallic pigments)
For multi-colored coatings, samples must be submitted separately for each color.
Contract Signing and Payment
The testing agency will provide a quote based on the complexity of the coating composition (approximately 800-1500 RMB for a single component, and approximately 1500-3000 RMB for multi-component or full SVHC testing). After confirmation, a service agreement will be signed and payment made.
3. Laboratory Testing Phase
Core Testing Items (Focusing on Coating Characteristics)
| Testing Category | Typical Detected Substances
| Substances of Very High Concern (SVHC) | Lead, Cadmium, Phthalate Esters (DEHP, DBP), Polycyclic Aromatic Hydrocarbons (PAHs), Isocyanates
| Heavy Metals | Soluble Lead, Chromium (VI), Mercury, Arsenic
| Volatile Organic Compounds (VOC) | Benzene, Toluene, Xylene, etc.
| Specific Restricted Substances | Asbestos, Azo Dyes (for Textile Coatings)
Testing Cycle
Routine SVHC Screening: 5-7 working days;
4. Report Issuance and Result Response
Compliance Report Content
Includes sample information, testing methods, concentration values of each substance, comparison with regulatory limits (e.g., whether SVHC < 0.1%), and conclusion (compliant/non-compliant).
Results Handling Plan
Compliant: The report serves as a customs clearance document and can be directly used for sales in the EU market; if the annual export volume is ≥1 ton, REACH registration must be completed simultaneously (submitted through the EU Sole Representative OR).
Uncompliant (e.g., SVHC exceeding limits):
1. Trace the source of the exceedance (e.g., pigment supplier, solvent batch)
2. Adjust the formulation (replace with low-risk alternatives, such as replacing phthalates with environmentally friendly plasticizers)
3. Resubmit samples for testing until compliant
5. Continuous compliance management
SVHC List Updates
The EU updates the SVHC list 2-4 times annually (increasing to 251 items by 2025). Testing for newly added substances must be completed within 6 months of the update.
Supply Chain Management
Require raw material suppliers to provide REACH compliance certificates and sign quality agreements clearly defining responsibilities for hazardous substance limits.
Notification Obligation
If the SVHC concentration in the coating is >0.1% and the annual export volume is >1 ton, a notification must be submitted to ECHA within 6 months of the substance being added to the list.
Special Considerations for Paint Companies
1. Additional Requirements for Solvent-Based Paints
Volatile Organic Compound (VOC) emission limits must be tested simultaneously (refer to EU Coatings Directive 2004/42/EC), such as VOC ≤ 150g/L for indoor paints.
2. Paints for Children's Toys
SVHC limits are stricter (e.g., lead content must be <0.01%), and must comply with EN 71-3 toy safety standards.
3. Data Sharing and Cost Optimization
If using the same paint formulation with other companies, testing costs can be shared (REACH regulations encourage data sharing to reduce duplicate testing).
If you need recommendations for specific testing institutions or detailed solutions for a particular type of paint (e.g., automotive paint, architectural paint), please let me know, and I will help you further refine your understanding.
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