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REACH is the chemical regulation of the European Union, which regulates “substances” rather than “whether a product is good or not”.Hot melt adhesive granulesAs a mixture exported to the EU, there are two core obligations: first, each substance in the formula must be registered or exempted from compliance on the EU side, and second, it must not contain substances of high concern (SVHC) that exceed the standard. The vast majority of EVA hot melt adhesive particles used in printing and packaging have low risks, and the shell often gets stuck in incomplete documents rather than unqualified products.
When Chinese factories export directly, the legal registration obligor is the EU importer, not the Chinese manufacturer. The actual responsibility of the manufacturer is to provide accurate composition and testing data, and cooperate with the importer to complete the declaration. If the client requests that you undertake the registration, it is usually necessary to designate a sole representative (OR) within the European Union. Clarifying the role can avoid being asked to do things that you shouldn’t have done.
The SVHC list of ECHA is updated twice a year (usually around January and June), and currently has over 200 items. The focus of hot melt adhesive particles should be on residual plasticizers such as phthalates, some flame retardants, and specific antioxidants. The testing commission shall be entrusted to a qualified third-party laboratory, and the report issued shall specify the version number and detection limit of the list on which it is based.
| project | conventional practice | Points to note |
|---|---|---|
| SVHC screening | Screen by the latest list for all items or by risk items | The report must indicate the list version and release date |
| Phthalate esters | GC-MS quantification | Food contact packaging is almost a must check for customers |
| heavy metal | Four or eight heavy metals | Toy and children’s book orders are often added |
| Report validity period | Generally updated annually | Formula changes require immediate retesting |
SDS sent to the EU must be written in accordance with the CLP regulatory format, consisting of 16 items, and the language must be the official language of the destination country. Common reasons for returns include: still using the old GHS format, conflicting hazard classification in Section 2 and components in Section 3, and lack of regulatory information in Section 15. It is recommended to entrust this step to a professional organization or a supplier with export experience.
List of ingredients, upstream REACH declaration, SVHC testing report SDS、 Each batch of COA shall be classified into the same set of files and filed according to the brand. When EU buyers or customs conduct spot checks, they can provide a complete set of documents within one day, which is much faster and more convincing than sending them for temporary inspection afterwards.
Q: How often should SVHC reports be redone?
Answer: After the list is updated, it is recommended to review it. When there is a change in the formula or raw material supplier, it must be retested. Usually, an annual update is sufficient.
Q: Just exporting books and magazines, the glue is already in the book, do we still need REACH?
Answer: As a finished product, the obligation is different from that of bulk adhesive, but EU buyers still generally require the SVHC declaration of the adhesive used. It is recommended to prepare it as usual.
Q: Can small batch exports eliminate testing?
Answer: The regulations do not exempt batches, but existing reports of the same brand can be reused without the need to redo each order.
Guangzhou Sunlife TradingSunlife Hot Melt AdhesiveWe provide ingredient descriptions, SVHC testing reports, and CLP format SDS support for printing and packaging customers with export needs. Common grades for export books, color boxes, and paper bags are readily available, which can significantly shorten the round-trip time between buyer factory review and customs clearance.
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