REACH Compliance for Pet Products Sold in Europe

REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is the EU chemical regulation that affects nearly every consumer product sold in the European Union. For pet products, REACH compliance is mandatory and often misunderstood. A factory claiming “REACH compliant” without the right documentation is exposing the importer to EUR 10 000+ fines and seized shipments. This article explains what REACH actually requires for pet products, what testing is needed, and how to verify factory claims. Written from Hefei, China, by Eviehome (Hefei Ecologie Vie Home Technology Co., Ltd.).

What is REACH

REACH is Regulation EC 1907/2006, adopted in 2006, governing chemicals placed on the EU market. Its goals are:

• Identify dangerous chemicals
• Restrict their use
• Require manufacturers to register and test chemicals used in consumer products
• Communicate information about hazardous substances through the supply chain
• Protect human health and the environment

For pet products, REACH mainly affects the restricted substances list and the Substances of Very High Concern (SVHC) reporting obligation.

Two key REACH obligations for pet product importers

1. Restricted substances (Annex XVII)

REACH Annex XVII lists substances that are restricted or banned in specific concentrations in consumer products. The list is updated regularly. Relevant restrictions for pet products include:

• Lead: maximum 0.05 to 0.1 percent in specific applications
• Cadmium: maximum 0.01 percent in plastics and jewelry-like items
• Phthalates: DEHP, DBP, BBP, DIBP restricted to below 0.1 percent in PVC plasticizers for certain products (especially products that may be chewed)
• Nickel release: restricted in items that contact skin for prolonged periods
• PAHs (Polycyclic Aromatic Hydrocarbons): restricted in rubber and plastic parts
• Azo dyes: restricted aromatic amines from dyes
• Formaldehyde: restricted in textiles and leather

If a pet product contains restricted substances above the limits, it cannot be sold in the EU. Compliance is mandatory.

2. Substances of Very High Concern (SVHC) reporting

REACH has a “Candidate List” of SVHCs (currently 230+ substances, updated twice yearly). If a product contains any SVHC above 0.1 percent by weight of the homogeneous component, the manufacturer/importer must:

• Inform the customer (for B2B) or consumer (for B2C) upon request
• If the product is manufactured in the EU, register the SVHC with ECHA (European Chemicals Agency)
• For imported products, submit a SCIP (Substances of Concern In articles as such or in complex objects) notification to ECHA since 2021

The SCIP database is a recent requirement that many first-time importers miss.

What REACH testing looks like

For a pet product, a REACH compliance test typically measures:

Heavy metals

Lead (Pb), Cadmium (Cd), Chromium VI (Cr6+), Mercury (Hg). Tested by ICP-OES or ICP-MS. Cost: USD 200 to 500 per sample.

Phthalates

DEHP, DBP, BBP, DIBP, DNOP, DINP, DIDP. Tested by GC-MS. Cost: USD 200 to 400 per sample.

SVHC screening

Full SVHC panel against the current Candidate List. Cost: USD 500 to 1 500 per sample depending on substance coverage.

PAHs and azo dyes (for applicable materials)

Cost: USD 300 to 600 per sample.

Total REACH testing cost for a pet product

USD 1 200 to 3 500 for a typical smart pet feeder with plastic housing, metal parts, and electronic components. Each material requires separate testing.

SCIP database obligations (since January 2021)

The SCIP database is a mandatory ECHA database tracking articles containing SVHCs. Importers must:

1. Identify any SVHC present above 0.1 percent in any homogeneous component of the product
2. Submit a SCIP notification with specific details about the article, the SVHC, and its location in the product
3. Update the notification if the product composition changes
4. Maintain the notification for the lifetime the product is on the EU market

SCIP notifications take 1 to 3 hours per SKU to prepare and submit. Small brands often outsource this to a REACH consultant for USD 200 to 500 per SKU.

REACH compliance documentation

For each REACH-compliant product, you should maintain:

• Test reports: from an accredited lab, covering all relevant substances
• REACH Declaration of Compliance: a single-page document signed by the manufacturer stating the product complies with REACH
• SVHC statement: listing any SVHCs present above 0.1 percent or confirming none are present
• SCIP notification reference number: if applicable
• Bill of Materials: listing all materials and their suppliers for traceability

EU customs authorities can request these documents at any time. Missing documentation leads to shipment delays or seizures.

How to verify factory REACH claims

Chinese factories commonly claim “REACH compliant” without proper documentation. Verification steps:

1. Request the full test report: not a summary or certificate, but the full lab report including methodology, results, and equipment.
2. Verify the lab is accredited: ISO 17025 accredited labs are acceptable. Chinese labs like SGS, TUV, Bureau Veritas are reliable.
3. Check the test date: REACH is updated regularly; old reports may not cover new SVHCs.
4. Verify the test covers your specific product: not a similar product from the factory’s catalog.
5. Check which materials were tested: all materials that contact the pet or the user need coverage.

Common REACH mistakes

• Assuming “RoHS compliance” covers REACH: they are different regulations covering different substances.
• Testing only the plastic housing: inks, adhesives, and electronics also contain regulated substances.
• Using old test reports for products with changed materials: if the plastic supplier changed, the test may no longer be valid.
• Skipping SCIP notification: mandatory since 2021, often missed.
• Not updating for new SVHCs: the list grows twice yearly; products need periodic re-review.

Cost of non-compliance

REACH violations can result in:

• Shipment seizure at EU customs (costs vary by country)
• Administrative fines up to EUR 100 000+ depending on severity and country
• Product withdrawal orders from national market surveillance
• Reputation damage from published non-compliance in EU enforcement databases
• Civil liability if consumers are harmed

Budget USD 1 500 to 4 000 per SKU for proper REACH compliance, which is much cheaper than any of the above.

Frequently asked questions

Does REACH apply to pet products specifically?

Yes. REACH applies to all consumer products sold in the EU, including pet products. There is no pet-specific exemption.

Can I rely on the factory’s REACH compliance documentation?

Only if the documentation is from an accredited lab, specific to your product, and current. Verify independently for the first PO, then trust for subsequent orders unless the factory changes materials.

Does Eviehome provide REACH-tested products?

Yes. All Eviehome products sold into the EU market are REACH-tested with documentation available to customers. See our certifications and quality page.

About Eviehome

Eviehome provides full REACH testing and SCIP compliance for EU-bound pet products. Based in Hefei, China since 2014.

Contact Ryan Lau at ryanlau@eviehometech.com, on WhatsApp at +86 199 5653 0913, or use the contact form.