Processing of EU REACH SVHC test reports for leather goods
Date：2026-03-06 09:59:37 Classification
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Obtaining a REACH SVHC (Substances of Very High Concern) test report for leather goods is a crucial compliance step for exporting leather goods to the EU. Below is a detailed guide, procedure, and precautions:
1. What is REACH SVHC Testing?
REACH Regulation: EU regulation concerning the registration, evaluation, authorization, and restriction of chemicals.
SVHC: Substances of Very High Concern. The European Chemicals Agency (ECHA) regularly updates the SVHC list (currently 253 items, data as of early 2026).
Requirements: If the SVHC content in a product exceeds 0.1% (by weight), and the annual export volume exceeds 1 tonne, notification to ECHA is mandatory; regardless of the export volume, sufficient information must be provided to the recipient to ensure safe use.
2. Common High-Risk Substances in Leather Goods
The following SVHC substances are easily introduced during the leather production process (tanning, dyeing, finishing, adhesives) and are key targets for testing:
Lead chromate, lead chromate molybdenum red: Commonly found in yellow, orange, or red pigments/coatings.
Phthalate esters: Commonly found in softeners and adhesives used in synthetic leather (PU/PVC).
Short-chain chlorinated paraffins (SCCP): Commonly used as leather fatliquoring agents or flame retardants.
Dimethyl fumarate (DMF): Commonly used for mildew prevention; although restricted by REACH, it remains an SVHC and exceeding limits is strictly prohibited.
Hexavalent chromium: Although mainly on the restricted substance list, it still requires close attention (especially for chrome-tanned leather).
Aromatic amines released from azo dyes: Some are SVHCs or restricted substances.
Bisphenol A (BPA): May be found in synthetic leather or certain coatings.
3. Application Process
Step 1: Determine Testing Items
Full Item Testing: Tests for all substances on the SVHC list (currently over 200). High cost, long processing time, suitable for situations where there is no understanding of the supply chain.
Screening Testing: Tests for high-risk substances commonly found in the leather goods industry. This is the choice of most companies, offering high cost-effectiveness.
Recommendation: Communicate with the testing agency and select the "Leather Goods Industry SVHC Package".
Step 2: Fill out the application form
Obtain the application form from a third-party testing agency (e.g., Dezewei Testing CNAS Registration No.: L8083).
Fill in the applicant information, manufacturer information, product name, model, etc.
Step 3: Sample preparation
Quantity: Usually, approximately 50g-100g of finished product or individual component materials are required.
Sampling principle: "Homogeneous material" principle.
If the leather goods are composed of multiple materials (e.g., genuine leather body + metal buckle + plastic lining + glue), different materials need to be tested separately.
For example: Test one sample for genuine leather, one for metal, and one for plastic.
Note: If materials of different colors have the same composition but different colors, they usually also need to be tested separately because pigments may contain different SVHCs. *
Step 4: Quotation and payment
The agency will issue a quotation based on the material quantity and testing items.
Payment after confirmation.
Step 5: Laboratory Testing
The testing cycle is typically 5-7 working days (depending on the number of projects).
Testing methods usually employ chemical analysis (such as GC-MS, ICP-MS, etc.).
Step 6: Report Issuance
Test Pass: A pass test report is issued.
Test Fail: The report will show the substances exceeding the limits and their concentrations. In this case, it is necessary to replace raw materials or processes, rectify the issues, and retest.
4. Cost Estimation
The cost depends on the quantity of materials tested and the test items:
Single-group material SVHC full-item testing: Higher cost, typically several thousand RMB.
Single-group material high-risk screening: Relatively lower cost, ranging from several hundred to over one thousand RMB.
Multi-material products: If leather goods contain multiple components such as leather, metal, and plastic, the cost is the sum of the costs of each material group.
5. Key Considerations
1. Distinguish between "Test Report" and "SVHC Notification":
The test report is a document proving product compliance.
1. **SVHC Content >0.1% and Annual Export Volume >1 Ton:** If an SVHC content of >0.1% is detected and the company's annual export volume is >1 ton, a formal notification to ECHA is required through an OR (Sole Representative). A simple test report is not equivalent to notification.
2. **Supply Chain Communication:**
Before submitting materials for testing, it is best to obtain REACH reports from raw material suppliers. If upstream suppliers can provide compliant reports, you can reduce the number of tests required for finished products, saving costs.
3. **List Updates:**
The SVHC list is updated every six months (usually in June and December). Ensure your report meets the requirements of the latest version. Customers may request an update if the report is outdated.
4. **Homogeneous Material Concept:**
Testing must be performed on homogeneous materials (materials that cannot be further separated by mechanical means). For example, a coating and a leather base that cannot be peeled off may be considered one material; if they can be peeled off, they must be tested separately.
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