Key takeaways
- 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](/blog/fda-food-contact-polymers)
- Safety Data Sheet (SDS) in the EU 2020/878 format
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.