REACH Compliance Process for Exporting Drinkware to the European Union

For B2B buyers, compliance is a gatekeeping issue: a tumbler can be food-contact safe and still fail a REACH document review. The good news is that REACH is manageable when treated as a supply-chain process rather than a last-minute certificate. LUCKCHEN, a stainless steel and plastic cup manufacturer with more than 20 years of R&D experience and LFGB and FDA certified drinkware, supports OEM and ODM programs for buyers who need product documentation aligned with multiple markets.

What REACH Requires for Drinkware Articles

REACH is Regulation (EC) No 1907/2006. It applies to chemical substances, mixtures and articles. Drinkware such as stainless steel tumblers, plastic cups and travel bottles is normally an article. For articles, three duties matter most:

• Identify Substances of Very High Concern (SVHC) on the ECHA Candidate List above 0.1% weight by weight per article.
• Communicate SVHC information through the supply chain under Article 33.
• Check Annex XVII restrictions and, where applicable, submit SCIP notifications for articles containing SVHC above the threshold.

REACH does not issue a single product certificate. A supplier may provide a REACH declaration, SVHC test report or material statement, but the legal responsibility for the EU import usually sits with the EU importer. A non-EU manufacturer can appoint an Only Representative to support obligations, but the importer remains accountable for the goods placed on the EU market.

Step-by-Step REACH Compliance Process

1. Confirm roles and responsibilities

Map who is the manufacturer, exporter, EU importer and Only Representative. Decide who will hold the bill of materials, who will request SVHC tests and who will file SCIP. For a private-label drinkware program, this should be agreed before purchase orders are issued.

2. Build a material breakdown for each SKU

REACH work starts with the bill of materials. For a product such as the Custom Double Wall Stainless Steel 20oz/30oz Sublimation Tumbler with Straw and Lid, model X94310344, the published specification identifies a stainless steel body and a PP lid, with BPA Free construction. The product is not dishwasher safe and not oven safe. Customization options include silk screen, laser printing, heat transfer, water transfer, air transfer and 3D decoration, plus color painting, powder coating, shiny painting, pearl painting, gradient color painting and rainbow color painting.

Each material and decoration route should be listed separately: stainless steel, PP lid, straw and lid assembly, inks, coatings and adhesives. If the straw material is not specified in the current specification, confirm it with the supplier before completing the REACH file. Packaging is generally assessed separately from the article, but buyers should still keep packaging material declarations on file.

3. Screen the ECHA Candidate List

Check the current Candidate List, not an old PDF. For each article, calculate whether any SVHC is present above 0.1% w/w. Pay attention to plastics, coatings, printing inks, seals and surface treatments. Stainless steel is often a lower-risk material for organic SVHC, but the full article must be assessed, including the lid, straw and decoration.

The output should be a clear SVHC statement: either no SVHC above 0.1% w/w, or a list of substances, locations and concentrations. Avoid generic statements such as REACH compliant without supporting data.

4. Review Annex XVII restrictions

Annex XVII lists restrictions on certain substances and mixtures. For drinkware, review restrictions that may apply to metals, plastics, coatings and printing inks. This is separate from the Candidate List. A product can pass SVHC screening and still need an Annex XVII check.

5. Test and document

Use a qualified third-party laboratory for SVHC screening when needed. The test report should identify the model, materials tested, test method, date and result. Keep material declarations from suppliers for stainless steel, PP, straw, inks and coatings. If a formulation changes, re-test or re-screen the affected components.

REACH documentation is not the same as food-contact documentation. EU food-contact compliance relies on the Framework Regulation (EC) No 1935/2004 and related measures such as Regulation (EU) No 10/2011 for plastics. Germany's LFGB is a food-contact standard, and LUCKCHEN's drinkware is LFGB and FDA certified. Those certifications support food-contact market access, but they do not replace a REACH SVHC file.

6. Prepare the REACH file

A practical file for an EU buyer usually includes:

• REACH declaration signed by the manufacturer.
• SVHC test report or material-based SVHC assessment.
• Bill of materials with material and coating details.
• Annex XVII review note.
• SCIP number if an SVHC is above 0.1% w/w.
• Food-contact declaration and migration test reports where relevant.

7. Communicate and notify

Under Article 33, recipients of an article containing an SVHC above 0.1%