REACH and RoHS Compliance for Masterbatch: SVHC, Heavy Metals, and Documentation

Chemical Compliance for Masterbatch in Global Markets

Masterbatch suppliers and plastic manufacturers selling into the EU and global markets face a complex web of chemical regulations. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and RoHS (Restriction of Hazardous Substances) are the two most significant, governing which substances may be used and at what concentrations. Compliance requires careful pigment and additive selection, testing, and documentation.

Non-compliance carries serious consequences — from border rejection to product recalls and regulatory penalties. Understanding REACH and RoHS is essential for any masterbatch buyer.

REACH: The EU Chemical Regulation

REACH (EC 1907/2006) requires manufacturers and importers to register substances produced or imported above 1 tonne per year. For masterbatch, the key REACH concepts are:

• Registration: Pigments and additives must be registered by their manufacturers.
• SVHC (Substances of Very High Concern): The Candidate List — substances requiring authorization or restriction. Currently over 240 substances.
• Restrictions (Annex XVII): Banned or restricted substances with specific limits.
• Article 33 communication: Suppliers must inform customers if SVHC content exceeds 0.1% w/w.

RoHS: Restriction of Hazardous Substances

RoHS (EU 2011/65/EU) restricts hazardous substances in electrical and electronic equipment. The original six restricted substances plus four phthalates (RoHS 3):

Pigments and Additives of Concern

Historically, several pigments contained restricted heavy metals. Modern masterbatch formulations avoid them entirely:

• Lead chromate pigments (yellow/orange): Now largely replaced by organic pigments or bismuth vanadate.
• Cadmium pigments (red/yellow): Restricted; replaced by organic alternatives.
• Mercury compounds: Banned in plastics.
• Hexavalent chromium: Not used in modern masterbatch.

Documentation Requirements

To prove compliance, masterbatch suppliers provide:

• REACH SVHC declaration: Confirming SVHC content below 0.1% w/w.
• RoHS certificate of conformity: Confirming compliance with RoHS limits.
• Heavy metal test reports: From accredited laboratories (XRF or ICP analysis).
• Full material disclosure (FMD): Complete ingredient list under NDA where required.

Conclusion

REACH and RoHS compliance requires disciplined pigment selection and thorough documentation. MHK Color formulates masterbatch with REACH-compliant, RoHS-compliant pigments and provides SVHC declarations and RoHS certificates for every product. Contact our regulatory team for compliance documentation or to discuss a specific market's requirements.