Key takeaways
- Any polymer entering the EU must clear two distinct frameworks — REACH (chemicals) and RoHS (electrical/electronic equipment); they overlap but are not the same.
- Under REACH the polymer itself is exempt, but its monomers and additives are not — get a grade/lot statement that names the additives and confirms SVHC status below the 0.1% w/w threshold.
- RoHS restricts ten substances in electrical/electronic equipment; most modern polyolefin and engineering grades comply by default, with lead-stabilised PVC the historical risk.
- File the compliance pack with each shipment — REACH statement, RoHS if the use is EEE, EU 10/2011 if food-contact, and an SDS in EU 2020/878 format. A missing SVHC statement can hold a container for weeks.
Any polymer that enters the European Union has to clear two regulatory frameworks: REACH and RoHS. They overlap and they are easy to conflate. They are not the same and a buyer signing for material in Rotterdam needs to confirm both.
REACH covers all chemical substances placed on the EU market in volumes above one tonne per year. For polymers the polymer itself is exempt from registration, but the monomers and additives that went into it are not. Antioxidants, slip agents, antiblock additives, UV stabilisers, and processing aids all need to be either pre-registered or covered by an exemption.
What this means at the buyer end: ask the producer for a REACH compliance statement that covers the specific grade and lot, names the additives, and confirms that none of them appear on the SVHC (Substances of Very High Concern) candidate list above the 0.1% w/w reporting threshold. SVHC lots that exceed the threshold trigger Article 33 disclosure obligations to downstream customers.
RoHS is a separate Directive that applies specifically to electrical and electronic equipment (EEE). It restricts ten substances — lead, cadmium, mercury, hexavalent chromium, four phthalates, and two brominated flame retardants — below specified thresholds. If the polymer is going into a finished EEE product, the buyer needs a RoHS declaration even if REACH is already in hand.
Most modern polyolefin and engineering grades are RoHS-compliant by default. The historical risk was lead-stabilised PVC, which is why the choice between S-PVC and E-PVC sometimes depends on where the producer’s stabiliser system is sourced from.
- REACH compliance statement, naming additives and confirming SVHC status
- RoHS declaration if the end-application is EEE
- Food-contact compliance statement (EU 10/2011) if relevant — see the food-contact primer
- Safety Data Sheet (SDS) in the EU 2020/878 format
These documents are not bureaucracy. EU customs run random checks, and a missing SVHC statement can hold a container at port for weeks. Build the compliance pack into the contract, not into the after-shipment scramble.
Frequently asked
Questions on the desk
What is the difference between REACH and RoHS?
REACH governs all chemical substances on the EU market — for polymers, the monomers and additives. RoHS is a separate directive that restricts ten hazardous substances specifically in electrical and electronic equipment (EEE). A grade can need both.
Are polymers registered under REACH?
The polymer itself is exempt from registration, but the monomers and additives that went into it — antioxidants, slip and antiblock agents, UV stabilisers, processing aids — must be pre-registered or covered by an exemption, and must not appear on the SVHC candidate list above 0.1% w/w.
What documents do I need to import polymer into the EU?
A REACH compliance statement naming additives and confirming SVHC status, a RoHS declaration if the end-use is EEE, an EU 10/2011 food-contact statement if relevant, and a Safety Data Sheet in the EU 2020/878 format.
What is an SVHC under REACH?
A Substance of Very High Concern. If an SVHC is present above the 0.1% w/w reporting threshold it triggers Article 33 disclosure obligations to downstream customers, so the producer's statement must confirm the lot is below it.
General market commentary from the OmniaStrata desk, provided for information only. It is not legal, financial, tax, or trading advice, and it is not an offer or a commitment to any terms. Figures such as price ranges, spreads, financing costs, and credit periods are illustrative market context, not OmniaStrata's rates or terms. Actual contract terms — including price, payment instrument, credit, insurance, and Incoterms — are agreed in writing on a per-transaction basis and at OmniaStrata's discretion. Market conditions change; figures reflect the publication date.