The EU is an attractive destination for Vietnamese plastic products, but it also sets the world’s highest technical bar on chemicals. The REACH Regulation (EC 1907/2006) governs chemicals in every product placed on the EU market, including imports. Enterprises unfamiliar with REACH risk rejected consignments or lost contracts.
1. How REACH applies to imported plastic products
REACH is the EU’s framework regulation on the registration, evaluation, authorization, and restriction of chemicals, covering nearly all products marketed in the EU. Finished plastic goods are classified as “articles” — objects given a specific shape during production — so chemicals embedded in plastics, such as plasticizers, stabilizers, and colorants, fall within its scope. The registration duty in principle rests on EU-established manufacturers or importers, not directly on exporters outside the EU. In commercial practice, however, EU importers always require Vietnamese suppliers to provide full composition information, safety data sheets, and commitments on restricted substances, because the importer bears legal responsibility before EU regulators.
2. The SVHC list and notification duties
The focal point for plastic enterprises is the list of substances of very high concern (SVHC) published and periodically updated by the European Chemicals Agency (ECHA). When an article contains a listed substance above 0.1% by weight, suppliers in the chain must pass safety information to recipients and, where conditions are met, notify ECHA. Because the list grows regularly, internal procedures should include reviewing blending formulas whenever materials or additives change, requiring SVHC commitments from resin and additive suppliers, and conducting periodic or spot testing at competent laboratories. Testing costs are always far lower than having a consignment recalled at an EU port.
3. Restrictions and building a compliance file
Beyond SVHC, REACH maintains a restriction list (Annex XVII) for substances restricted or banned in specific product groups — for example, certain phthalates restricted in toys and childcare articles. Enterprises must map each product line against the currently effective list, since a substance allowed in industrial packaging may be banned in children’s goods. On documentation, assemble a file with the raw-material composition table, input safety data sheets, test results for SVHC and restricted substances, and a compliance declaration for the EU partner. Equally important is inserting a REACH compliance warranty into the sales contract: who is responsible if a violation is found, the inspection mechanism, and how recall costs are shared — preventing disputes when a shipment runs into trouble.
Conclusion
REACH is not an insurmountable barrier but a rulebook that plastic exporters to the EU must know by heart. Mastering the registration mechanism, tracking the SVHC list, checking the restriction list, and preparing a complete compliance file will help hold the EU market and turn compliance into a competitive edge.
Frequently asked questions
1. Must a Vietnamese enterprise register directly under REACH?
Usually not. The REACH registration duty falls on manufacturers or importers established in the EU. Vietnamese exporters of plastic products should work with their EU importer to determine who bears the registration responsibility, while supplying complete product composition information so the partner can fulfill the duty. In some models, the enterprise may appoint an only representative in the EU.
2. What if a plastic product contains SVHC above 0.1%?
When an article contains a candidate-list SVHC above 0.1% by weight, the supplier must provide safety information to recipients down the supply chain and, where conditions are met, notify the European Chemicals Agency (ECHA). Exporters need to control blending formulas, require SVHC commitments from material suppliers, and test when necessary.
3. How can the latest SVHC candidate list be checked?
The SVHC candidate list is updated periodically by ECHA, usually twice a year. Enterprises should consult ECHA’s official information pages before each export shipment or whenever materials or additives change. Relying on an old saved copy is risky because a newly added substance can trigger fresh notification duties.
4. Does REACH ban any substances in plastic goods?
REACH maintains a restriction list (Annex XVII) naming substances restricted or banned in specific product groups and uses, for example certain phthalates in toys and childcare articles. Enterprises must map each of their plastic product lines against the current restriction list instead of assuming that everything is either banned or allowed.
5. What dossier proves REACH compliance?
A compliance file typically includes the raw-material composition table, safety data sheets (SDS) of inputs, test results for SVHC and restricted substances, and a REACH compliance declaration sent to the EU partner. These documents also support inserting a REACH compliance warranty clause into the sales contract, allocating responsibility if a dispute arises.
This article has been quality-reviewed by the FLAW AI Legal Council.
