REACH Regulation · Home Decoration
REACH is the abbreviation for the EU's Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals, with the regulation number (EC) No 1907/2006. It officially entered into force on June 1, 2007, and is uniformly supervised by the European Chemicals Agency (ECHA, headquartered in Helsinki, Finland). It is the largest and most complex chemicals management regulation in the EU to date, with the core logic of "No Data, No Market" — any chemical substance manufactured or imported in the EU in quantities exceeding 1 tonne per year must complete registration before it can legally circulate.
For Chinese custom home furnishing companies, REACH is not "something only chemical companies need to worry about." When custom home furnishing products — wardrobes, cabinets, wooden doors, bathroom vanities, panels, edge banding, adhesives, paints and coatings, hardware, and soft furnishing accessories — are exported to the EU, virtually all of them will touch upon REACH's Article provisions. In particular, the SVHC (Substances of Very High Concern) list and Annex XVII Restricted Substances List are the two "measuring sticks" most frequently checked by EU customs, buyer QA departments, and third-party testing institutions.
In terms of scope of application, REACH covers the 27 EU member states and the European Economic Area (EEA) countries of Norway, Iceland, and Liechtenstein. After Brexit, the UK separately implements UK REACH, whose rules are highly similar to EU REACH but operate independently. As long as products enter the above markets, whether you export directly, re-export through traders, or perform OEM/ODM manufacturing for European brands, compliance responsibility will be transmitted along the supply chain to Chinese factories.
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SVHC (Substances of Very High Concern) is periodically updated by ECHA, and the list currently exceeds 240 items (as of 2024, the list continues to be updated on a rolling basis, and companies should refer to the latest version on the ECHA official website). SVHC commonly found in home furnishing products include:
| Substance Category | Typical Substances | Common Home Furnishing Components |
|---|---|---|
| Phthalates | DEHP, DBP, BBP, DIBP | PVC edge banding, soft plastics, coatings |
| Flame retardants | SCCP, MCCP | Upholstered fabrics, foam |
| Heavy metals | Lead, cadmium and their compounds | Hardware, pigments, solder |
| Polycyclic aromatic hydrocarbons | Benzo[a]pyrene and 7 others | Rubber handles, plastic foot pads |
| Organotins | Tributyltin | Coatings, PVC |
Key threshold: When SVHC concentration in an article is > 0.1% (w/w), two obligations are triggered — information transmission (providing safe use information to downstream customers) and SCIP notification (submitting to ECHA's SCIP database). If annual export volume is > 1 tonne/year, SVHC notification to ECHA is also required.
Annex XVII lists substances that are prohibited or restricted for use. Unlike the "information disclosure" logic of SVHC, it is a hard red line. High-frequency entries in the home furnishing industry include:
Products violating Annex XVII can be directly detained or destroyed by EU customs, and importers face fines or even criminal liability.
Since January 5, 2021, articles containing SVHC > 0.1% must submit notifications to ECHA's SCIP database before being placed on the EU market. SCIP stands for "Substances of Concern In articles as such or in complex objects (Products)." The notifying entity is the supplier within the EU (importer, assembler, brand owner), but the data source is highly dependent on the BOM (Bill of Materials) and test reports provided by Chinese factories. In practice, European buyers push the responsibility for SCIP data preparation onto Chinese suppliers.
Most custom home furnishing companies, as "article" suppliers, do not directly bear substance registration obligations. However, the following situations are exceptions:
A complete set of REACH compliance evidence typically includes:
1. SVHC screening report (issued by SGS, TÜV, Intertek, etc., with item-by-item testing against the latest list)
2. Annex XVII conformity declaration
3. SCIP notification number (if applicable)
4. Supply chain declaration (signed by upstream panel, adhesive, and hardware suppliers)
5. MSDS/SDS (for mixtures such as adhesives and coatings)
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| Dimension | EU REACH | Chinese GB Standards | US TSCA / CA Prop 65 |
|---|---|---|---|
| Regulatory logic | Precautionary principle, burden of proof on enterprises | Primarily standard conformity | TSCA regulates new chemical substances; Prop 65 regulates warnings |
| SVHC/substances of concern | 240+ items with rolling updates | Limited substance list | Prop 65 approximately 900+ items |
| Information disclosure | Mandatory SCIP database notification | No corresponding mechanism | No corresponding mechanism, but warning labels required |
| Consequences of violation | Customs detention, fines, criminal liability | Random inspection, rectification, fines | High risk of class action litigation |
| Pressure on Chinese factories | High (transmitted by buyers) | Medium | Medium-high (California market) |
Conclusion: REACH is the system among the three with the "heaviest procedures, fastest updates, and deepest transmission." If Chinese custom home furnishing companies serve both EU and North American markets, it is recommended to use REACH as the compliance baseline and be upward compatible.
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Case One: PVC Edge Banding Triggers SVHC Notification
A custom wardrobe company exported cabinet bodies to Germany, with edge banding made of PVC material. The German importer discovered during SCIP notification that DEHP content in the edge banding exceeded 0.1% and required the Chinese factory to provide an alternative solution. The company ultimately switched to ABS edge banding and supplemented third-party test reports before resuming shipments. Such problems erupted intensively after SCIP went live in 2021 and are one of the most publicly discussed compliance pain points in the industry.
Case Two: Flame Retardant Issue in Upholstered Nightstands
For upholstered nightstands exported to France, short-chain chlorinated paraffins (SCCP) were detected in the fabric. SCCP has been listed in Annex XVII and the POPs Regulation ((EU) 2019/1021), constituting a double red line. The goods were detained at the Port of Rotterdam, and the importer demanded the entire batch be returned. The company subsequently established a REACH access audit checklist for fabric suppliers.
Case Three: Lead Content in Hardware Handles
For a cabinet company's metal handles, due to the use of recycled copper alloy, lead content exceeded 0.05%, failing to comply with Annex XVII Entry 63. Although the amount was not large, it resulted in the entire container being required for rectification. Thereafter, the company included all hardware in its annual REACH spot-check plan.
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Q1: We only export finished products, not chemicals. Is REACH relevant to us?
Yes. REACH covers "articles," and custom home furnishing panels, adhesives, coatings, plastic parts, and hardware may all contain SVHC or restricted substances. EU buyers will write compliance responsibility into procurement contracts.
Q2: How often is the SVHC list updated? How do we keep up?
ECHA typically updates 1–2 times per year, adding several items each time. It is recommended to subscribe to ECHA official website email notifications or entrust testing institutions to provide list update reminders. Internally, a management mechanism of "list version number + test report validity period" should be established.
Q3: Whose responsibility is SCIP notification? Do Chinese factories need to do it?
The legal entity is the supplier within the EU. However, Chinese factories need to provide BOM, material declarations, and test reports; otherwise, European buyers cannot complete the notification. In practice, many buyers require Chinese factories to organize SCIP data packages on their behalf.
Q4: Do test reports have an expiration date?
REACH reports have no statutory expiration date, but buyers typically require reports within 1 year, and old reports may become invalid after the SVHC list is updated. It is recommended to update annually and conduct additional testing when there are major list updates.
Q5: Do UK REACH and EU REACH need to be done separately?
Yes. After Brexit, UK REACH operates independently, and the SVHC list and notification mechanism are not fully synchronized with the EU. Exports to the UK require separate compliance, and EU REACH documents cannot be directly reused.
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1. Establish a REACH compliance ledger: Record the SVHC screening status and report validity period of each material across three dimensions: product line, component, and supplier.
2. Write REACH clauses into supplier contracts: Require panel, adhesive, edge banding, hardware, and fabric suppliers to provide conformity declarations and test reports, with clear breach compensation terms.
3. Conduct a full SVHC screening annually: Focus on testing four high-risk component categories: PVC, upholstery, coatings, and metal parts.
4. Assign a dedicated person to track ECHA list updates: Complete internal impact assessment within 30 days after the SVHC list is updated.
5. Prepare SCIP data packages in advance: Organize BOM, materials, and SVHC content in ECHA format and proactively provide them to European buyers.
6. Prioritize substitution of high-risk substances: For example, replace PVC edge banding with ABS/PP, and replace solvent-based coatings with water-based coatings.
7. Choose testing institutions with EU qualifications: Reports issued by SGS, TÜV, Intertek, BV, etc., have higher recognition in the EU.
8. Distinguish between EU REACH and UK REACH: Prepare compliance documents separately for the UK market to avoid "one set of documents for all markets."
REACH is not a one-time "customs clearance exam" but continuous compliance throughout the entire product lifecycle. For Chinese custom home furnishing companies, whoever first turns REACH compliance into a supply chain capability will win more orders in buyer audits in the EU market.