The REACH 173 test report is a compliance report issued after testing chemical substances in products based on the relevant requirements of Article 173 of the EU “Registration, Evaluation, Authorization and Restriction of Chemicals” (REACH Regulation). The following is a detailed description of the regulatory background, core content, test points and report functions:

### **I. Regulatory background and purpose**
REACH Regulation (EC 1907/2006) is an important EU regulation on chemical management, aimed at protecting human health and environmental safety and promoting the safe use of chemicals. Article 173 clarifies the restrictions on certain hazardous chemicals and stipulates that if a product contains chemical substances restricted by the regulation and exceeds the limit, it will be prohibited from being sold in the EU market. The core purpose of the REACH 173 test report is to prove that the product meets these restrictions and ensure its compliance in the EU market.

### **Second, core content of testing**
#### 1. **Restricted substances list**
The restricted substances list (Annex XVII) of REACH 173 is updated regularly, covering hundreds of chemical substances that are harmful to human health or the environment. Common categories include:
– **Heavy metals and their compounds**: such as lead, cadmium, mercury, hexavalent chromium, etc. (for example, the cadmium content in leather is limited to ≤0.1%).
– **Phthalates**: such as DEHP, BBP, DBP, DIBP, etc. (some phthalates in toys or children’s products are limited to ≤0.1%).
– **Azo dyes**: azo dyes that can decompose carcinogenic aromatic amines (limit ≤30ppm).
– **Flame retardants**: such as polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), etc. (restricted use in electronic and electrical products).
– **Other hazardous substances**: formaldehyde, asbestos, nickel release, pentachlorophenol, etc. (for example, the formaldehyde content in textiles is limited from 20ppm to 300ppm depending on the purpose).

#### 2. **Test objects and scope**
– **Product types**: Almost all consumer products, including electronic appliances, toys, textiles, leather, furniture, building materials, cosmetic packaging, etc.
– **Test focus**: Analyze the content of restricted substances in the material components of the product, such as coatings, plastics, metals, rubber, fabrics, etc.

### **III. Limit standards and test methods**
#### 1. **Limit requirements**
The limit values ​​of different substances in different products vary greatly, for example:
– **Lead**: The lead content limit in electronic and electrical products is ≤0.1% (except for exemptions); the lead content limit in toy materials is ≤90ppm (0.009%).
– **Cadmium**: The cadmium content in general consumer products is limited to ≤0.01% (100ppm), and specific materials such as plastics and coatings may have more stringent requirements.
– **Phthalates**: The total limit of DEHP, BBP, DBP, and DIBP in toys and child care products is ≤0.1%.

#### 2. **Detection methods**
Common standards include:
– **Heavy metal detection**: such as EN 1122 (determination of cadmium in plastics), ISO 17294 (heavy metal detection in water quality), USEPA 3050B (heavy metal digestion in solid waste), etc.
– **Organic compound detection**: such as gas chromatography-mass spectrometry (GC-MS), high performance liquid chromatography (HPLC), etc., used to analyze phthalates, azo dyes, etc.

### **Fourth, the role of the report and applicable scenarios**
#### 1. **Required documents for market access**
– If companies want to sell products to the EU market, the REACH 173 test report is a key document to prove that the product complies with the restrictions of Annex XVII, which can avoid fines (up to 4% of the company’s global turnover), product recalls or market bans due to violations.
– E-commerce platforms (such as Amazon Europe and eBay) usually require sellers to provide this report to ensure product compliance.

#### 2. **Supply chain compliance management**
– The report can help companies screen for hazardous substances in raw materials and components, promote supply chain source control, and reduce compliance risks.
– For traders or brand owners, the report is also an important basis for proving product safety to customers and enhancing market trust.

### **V. Differences from other tests**
– **Differences from California 65**: REACH 173 is an EU regulation, covering a wider range of substances, with more detailed limits, and emphasizing the registration and evaluation of all links in the supply chain; California 65 is a local regulation in California, USA, focusing on carcinogenic and reproductive toxic substances, with warning labels and limit control as the main focus.
– **Differences from REACH SVHC**: The REACH SVHC (Substances of Very High Concern) list is used for notification and information disclosure, while REACH 173 is a mandatory restriction. If the limit is exceeded, sales are prohibited. The two belong to different compliance requirements in the regulations (SVHC focuses on transparency, and 173 focuses on prohibition of use).

### **Summary**
REACH 173 test report is an important compliance document for EU market access. By testing restricted substances in products, it ensures that they meet the limit requirements of Annex XVII, helps companies avoid legal risks, and ensures the legal circulation of products in the EU. Since regulations will continue to be updated, companies need to pay attention to changes in the restricted substance list and update tests in a timely manner to meet the latest requirements.