Compliance
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.
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.
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.
| Substance family | Function | Where it turns up |
|---|---|---|
| Phthalates (e.g. DEHP, DBP, DIBP) | Plasticiser | Soft PVC trims, some low-cost TPU blends, printed plastisol |
| Short-chain chlorinated paraffins | Flame retardant / plasticiser | Recycled or reclaimed polymer |
| Lead and lead compounds | Pigment, stabiliser | Bright yellows and reds, brass-coloured inserts |
| PAHs | Contaminant of carbon black | Black rubberised grips and soft-touch coatings |
| Nickel | Plating | Metal 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.
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 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.
Four things make a declaration worth the paper:
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.
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.
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.
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.