XRF · Dongguan, China

Compliance

REACH SVHC and SCIP: The Paperwork Behind One Phone Case

21 October 2026

"REACH compliant" is the most over-used phrase in a Chinese factory quotation. It usually means one thing: nobody has checked. For a phone case the substance question is narrow but real, and the paperwork that answers it is cheap if you plan it at sampling stage and expensive if you plan it after a customer complaint.

The rule, in one paragraph

If an article contains a substance on the ECHA candidate list above 0.1% by weight of that article, the supplier has to give the recipient enough information for safe use. The threshold is per article, not per shipment and not per homogeneous material — although in practice you measure materials, then reason about the article.

What counts as "the article"

A phone case sold as one unit is a complex object. The relevant units are usually:

This matters because 0.1% of a 30-gram case is 30 mg, while 0.1% of a 2-gram magnet assembly is 2 mg. A substance can be irrelevant in the shell and decisive in the insert.

Where SVHCs actually hide in a phone case

Substance familyFunctionWhere it turns up
Phthalates (e.g. DEHP, DBP, DIBP)PlasticiserSoft PVC trims, some low-cost TPU blends, printed plastisol
Short-chain chlorinated paraffinsFlame retardant / plasticiserRecycled or reclaimed polymer
Lead and lead compoundsPigment, stabiliserBright yellows and reds, brass-coloured inserts
PAHsContaminant of carbon blackBlack rubberised grips and soft-touch coatings
NickelPlatingMetal ring, button covers — relevant under restriction, not the candidate list

None of these are inevitable in a well-controlled process. All of them are possible in a process that buys pigment on price.

Article 33: the duty to tell your customer

If the threshold is exceeded, you must give the recipient sufficient information to use the article safely, including at minimum the substance name — and you must do it free of charge, within 45 days of a request at the latest. For consumer sales, that duty runs to the consumer.

The form is flexible: a line on the packaging, a leaflet, a web page referenced from the label. What is not acceptable is "we will answer if asked" with nobody able to answer.

SCIP: the extra step for the EU

SCIP is the ECHA database for articles containing candidate-list substances. Since 2021, EU suppliers of such articles must notify before putting them on the market. In practice this sits with the EU importer or the only representative — another reason the importer-of-record question and the compliance question are the same conversation.

Practical sequencing: screen the design → test the parts that can carry a substance → if nothing is above threshold, keep the report and move on → if something is, decide between reformulating and notifying. Notification is a permanent obligation; reformulating is a one-off cost.

What a usable declaration looks like

Four things make a declaration worth the paper:

  1. Scope. Which parts, which materials, which SKU. "All our products" is not a scope.
  2. Substance list version. The candidate list is updated twice a year; a 2019 report does not cover a 2026 question.
  3. Laboratory and date. An accredited lab, a report number, a date you can put in a file.
  4. Detection limit. Below the limit of detection is different from below 0.1%, and buyers who know the difference will ask.

Our position, stated honestly

We hold test reports for the materials we buy, and we will send them. We will not send a certificate with another company's name on it, and we will not describe a RoHS report as a REACH declaration — they cover different substance lists and different legal duties. If a buyer needs a full SVHC screen on a specific SKU, that is a chargeable test with a lead time, and it is cheaper to do once for a family of products than repeatedly for single orders.

If you are building a compliance file, start from a narrow SKU set in the iPhone range and reuse the results across colourways of the same material.

Questions buyers actually ask

Is a RoHS report enough for REACH?

No. RoHS restricts ten substances in electrical and electronic equipment; REACH covers the candidate list plus restrictions that apply to any article. A phone case is not in scope of RoHS as EEE, so a RoHS report is not the right document in the first place.

Do I need SCIP if I am the importer?

Yes, if the article contains a candidate-list substance above 0.1%. The obligation sits with the EU supplier of the article, which in an import scenario is normally the importer.

How often should the declaration be refreshed?

At every candidate-list update that could affect your materials, and at any change of material supplier. Practically, annual refresh plus a change-control clause with your factory.

Working on a first order? Send the models, quantities and destination country and we will quote against the terms described here — MOQ, tooling and Incoterm in one sheet.
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