SWTC SWC · Italy

意大利客户突然要REACH SVHC报告?先别急着送样,这三个坑我见一次赔一次

Italy is currently being quite rigorous in checking REACH SVHC, especially for leather goods, footwear, plastic parts, and textiles. Simply put, it governs whether your product contains SVHCs (Substances of Very High Concern). The current list has over two hundred substances, and the EU updates it twice a year. Italian customs and customers during inspections may both require you to provide a report. It is not a self-declaration like CE; it must be screened by a third-party laboratory according to the logic of the SCIP database. Do not assume that only chemicals need this—finished products containing plastics, coatings, inks, or adhesives may all be required to comply.

There are three most common pitfalls. First, the customer only says "REACH is required" without specifying whether it is SVHC screening or Annex XVII restricted substances. You go with the cheaper option, but it turns out the other party wants the full set, and you waste money. Second, sloppy sample handling—for example, testing the sole and upper separately but writing only one homogeneous material in the report. Italy will not accept that; it must be broken down by homogeneous material with details. Third, using the wrong list version. It was just updated in January 2024. If you issue a report based on an old list, the customer will reject it outright. I have seen a factory whose entire shipment was stuck at the Port of Genoa and eventually destroyed because one phthalate in the ink was not screened out.

On turnaround time, routine SVHC screening starts from receipt of samples and reports are issued in 5 to 7 working days. If complex disassembly is involved or mixed testing confirmation is needed, it is normal for it to drag out to 10 days. Do not believe in "certificate in three days"—that is basically template filling. I suggest you sort out the BOM and homogeneous material list in advance and ask the customer for the list of laboratories they recognize. Italian customers usually recognize SGS, TÜV, and Intertek. In addition, the report must have a summary page in Italian or English. They cannot understand a Chinese-only report, and going back and forth to supplement translations will delay another week.

One final reminder: SVHC is not "pass once and pass forever." Once the list is updated, it must be reassessed. If you have Italian orders on hand, first dig out last year's reports and check the dates. Do not wait until the customer urges you before taking action.

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