Process for Obtaining EU REACH Compliance Reports for Accessory Charms/Pendants
Date：2026-09-20 09:37:25 Classification
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Process for Obtaining EU REACH Compliance Reports for Accessories and Charms
Accessories and charms (such as necklaces, bracelets, earrings, keychains, and mobile phone charms) are typically composed of materials including metal, plastic, leather, rubber, and textiles. As "articles" exported to the EU, they are subject to REACH compliance obligations. Core Compliance Process
1. Determine REACH Obligations
Accessories/pendents are classified as "Articles" under REACH, not as chemical substances.
Identify SVHCs (Substances of Very High Concern) from the Candidate List present in each material (ECHA has currently listed over 253 SVHCs).
Key concentration threshold: Any substance content ≥0.1% (w/w) triggers obligations for information communication and notification.
2. Screening and Testing
Collect the product Bill of Materials (BOM) and request SDS (Safety Data Sheets) and REACH declarations from suppliers.
Focus screening on materials such as: metal plating (lead, cadmium, and nickel release), plastics (phthalates), leather/textiles (azo dyes), soldered joints, etc.
Commission a third-party laboratory with CNAS/CMA accreditation to conduct chemical testing and verification (Dezewei Testing CNAS Registration No.: L8083).
3. Compile Technical Documentation
Product material composition list and supplier information.
Laboratory test reports.
Explanation of SVHC screening results.
Risk assessment and application of exemption clauses.
4. Fulfill Information Communication and Notification Obligations
Communication downstream (Article 33): If SVHC content ≥0.1%, safe-use information for the substance must be provided to EU customers or consumers (free of charge within 45 working days).
Notification to ECHA (Article 7(2)): If SVHC content ≥0.1% and annual export volume >1 tonne, a notification must be submitted within 6 months.
5. Affix Compliance Markings and Archive Records
Add EU Authorized Representative information to product packaging or manuals (mandatory for non-EU manufacturers since 2021).
Retain technical documentation for 10 years for review by market surveillance authorities.
Special Considerations
| Key Item | Description
| Material Risk Level | Metal plating, plastics, and leather are "high-risk areas" for accessories; heavy metal release and excessive phthalate levels are the most common issues.
| Nickel Release Test | Pendants with prolonged skin contact must also comply with the nickel release limit requirements set out in REACH Annex XVII, Entry 27.
| Test Items | It is recommended to include at least: heavy metals (Pb, Cd, Ni), phthalates, azo dyes (for dyed materials), and polycyclic aromatic hydrocarbons (PAHs).
| Report Validity | Valid indefinitely provided materials/processes remain unchanged; re-evaluation is required if the supplier changes.
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