[Home](/)/[Resources](/resources)/UK Restricted Substances Chemical Testing

UKChemical Compliance

# UK Restricted Substances Chemical Testing: RoHS, REACH, and Children's Toys

Getting chemical substance testing right for the UK market means understanding three distinct frameworks that operate side by side: UK RoHS for electrical and electronic equipment, UK REACH for substances of very high concern in articles, and the BS EN 71 toy safety series for children's products. Each has its own scope, test methods, and documentation requirements — and each can fail independently. This guide walks through the practical testing process, from supply chain data collection through UKAS-accredited lab commissioning to compliance dossier assembly.

Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fuk-restricted-substances-chemical-testing)

At a glance

UK RoHS

Same 10 substances as EU RoHS

UK REACH SVHC

Disclose >0.1% in article on request

Toy chemical testing

BS EN 71-3 migration limits

Lab accreditation

UKAS ISO/IEC 17025 for UK

## Key frameworks and what they restrict

### UK RoHS — retained from EU law

The UK's RoHS requirements are maintained via the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (SI 2012/3032), as amended by the RoHS (Amendment) (EU Exit) Regulations 2019. These UK RoHS Regulations restrict the same 10 substances as EU RoHS 2 (as amended by (EU) 2015/863): lead (Pb) at 0.1%, mercury (Hg) at 0.1%, cadmium (Cd) at 0.01%, hexavalent chromium (Cr VI) at 0.1%, polybrominated biphenyls (PBB) at 0.1%, polybrominated diphenyl ethers (PBDE) at 0.1%, and the four phthalates (DEHP, BBP, DBP, DIBP) each at 0.1%. The MCVs apply at the homogeneous material level — identical to EU RoHS. The UK Government has indicated it will keep UK RoHS aligned with EU RoHS, but any future EU amendments do not automatically apply in the UK — manufacturers should monitor UK government announcements on substance additions.

### UK REACH — the retained EU REACH framework

Following Brexit, EU REACH (Regulation (EC) No 1907/2006) was retained in UK law as UK REACH through the European Union (Withdrawal) Act 2018 and subsequent UK REACH regulations (SI 2020/1577, as amended). UK REACH operates through the Health and Safety Executive (HSE), which manages the UK chemicals register and maintains the UK REACH SVHC (Substances of Very High Concern) Candidate List and Authorisation List. Article 33 of UK REACH requires suppliers of articles containing SVHCs above 0.1% by weight of the article to provide SVHC information to customers and consumers on request within 45 days. The UK SVHC Candidate List and the EU SVHC Candidate List have diverged slightly since Brexit — manufacturers should check both lists if supplying to both markets. HSE publishes the current UK REACH SVHC list at hse.gov.uk.

### Children's toys — BS EN 71-3 migration limits for heavy metals

BS EN 71 Part 3 (Safety of Toys: Migration of Certain Elements) specifies limits for migration of 19 elements from toy materials. This is a chemical safety test, not a total content test — it measures how much of a substance migrates from the toy material in an acid extraction simulating ingestion. The 19 elements include: antimony (Sb), arsenic (As), barium (Ba), cadmium (Cd), chromium (Cr, separately total Cr and Cr VI), cobalt (Co), copper (Cu), lead (Pb), manganese (Mn), mercury (Hg), nickel (Ni), selenium (Se), strontium (Sr), tin (Sn), organic tin (OT), and zinc (Zn). Category I (dry, brittle, powder-like, or pliable toy material), Category II (liquid or sticky toy material), and Category III (scraped-off toy material) have different migration limits — Category II limits are substantially more permissive than Category I due to different bioavailability. Lead migration limit under BS EN 71-3 for Category I material is 2.0 mg/kg — far more stringent than RoHS's total content limit of 0.1% (1000 mg/kg) because this is a migration/bioavailability measure.

### Polycyclic Aromatic Hydrocarbons (PAHs) in consumer articles

PAHs are a group of substances of concern in consumer products — particularly products with rubber, plastic, or elastomer components that come into prolonged skin contact, such as handles, grips, and wristbands. UK REACH Annex XVII (restriction entries) includes Entry 50 restricting PAHs in articles for consumers and toys. 16 PAHs are listed; the most commonly tested are benzo\[a\]pyrene and benzo\[e\]pyrene, with a combined limit of 1 mg/kg for articles intended for prolonged or short-term skin or oral contact. Many consumer electronics accessories — phone cases, earphone ear cushions, sports wristbands — contain rubber or soft plastic components and may require PAH testing for UK market compliance. Testing is done by GC-MS per the relevant technical specification.

### Commissioning accredited chemical testing in the UK

For UK market compliance, chemical test reports must generally be from laboratories accredited to ISO/IEC 17025 by UKAS (United Kingdom Accreditation Service) for the specific test methods being conducted. UKAS-accredited labs include Intertek (Nottingham, Milton Keynes), Eurofins (UK laboratories), SGS (various UK sites), TÜV Rheinland UK, and Element Materials Technology. For EU market compliance, reports from ISO/IEC 17025-accredited labs anywhere in the EU are accepted — the same lab (if UKAS and EA-accredited) can typically provide reports valid for both markets. Test reports should clearly identify: the test method (e.g., IEC 62321-4 for metals by ICP-OES), the scope of accreditation confirmation, the sample identification, the measured result, the uncertainty of measurement, and the comparison against the applicable limit. Ambiguous test reports — without method identification, uncertainty, or explicit limit comparison — are not fit for compliance purposes.

### PFAS restrictions coming to UK — monitoring requirements

Per- and polyfluoroalkyl substances (PFAS) are an emerging restriction area in both EU and UK chemical regulation. The EU PFAS restriction under REACH Annex XVII (a broad restriction on PFAS in consumer and professional products above defined thresholds) is one of the most significant chemicals restrictions in recent years, and the UK government has stated it will assess whether to maintain alignment with EU PFAS restrictions under UK REACH. PFAS are present in many electronics applications: water-repellent coatings, fluoropolymer cable insulation (PTFE, FEP), and some semiconductor manufacturing chemicals. UK manufacturers and importers should begin supply chain mapping to identify PFAS presence in products and materials ahead of any restriction entry into force. Testing is done by liquid chromatography mass spectrometry (LC-MS/MS) methods.

## How to run a UK chemical compliance programme

01

Identify the applicable UK restricted substances frameworks for your product category: UK RoHS (for EEE), UK REACH Article 33 (for SVHCs in articles), UK toy safety regulations (BS EN 71 series for toys), and any category-specific restrictions (PAHs under UK REACH Annex XVII Entry 50 for rubber/plastic consumer contact articles, phthalates for toys and childcare articles).

02

Obtain material declaration data from your supply chain using a structured format — IPC-1752A (for electronics components) or IEC 62474 (for electrotechnical product material declarations) are standard formats. Request full material composition from direct-material suppliers, with special attention to plastic compounds, surface coatings, solder alloys, rubber seals, and cables.

03

Review supplier material declarations for red-flag substances. Look for: any indication of lead (Pb), cadmium (Cd), phthalates (DEHP, DBP, BBP, DIBP) in plastics; hexavalent chromium in surface coatings; mercury in lamp assemblies or switches; PBB/PBDE in polymer flame retardants; nickel in skin-contact metal surfaces (UK REACH Annex XVII Entry 27); PAHs in rubber or soft plastic parts.

04

Commission XRF screening for metal-containing restricted substances (Pb, Cd, Hg, Cr, Br) on high-risk components. XRF gives rapid non-destructive results but cannot detect phthalates, Cr(VI) specifically, or PAHs. Use XRF results to triage — materials well below MCV limits need no further testing; materials near or above require confirmatory wet chemistry.

05

Commission confirmatory wet chemical testing at a UKAS-accredited laboratory for substances identified as potentially non-compliant by XRF screening or supplier declarations. Specify the exact test methods: IEC 62321-4 (ICP-OES for metals), IEC 62321-7-1 (Cr VI), IEC 62321-8 (phthalates by GC-MS), IP346 or GC-MS per technical specification for PAHs.

06

For toy products: commission BS EN 71-3 migration testing at a UKAS-accredited toy safety laboratory. BS EN 71-3 testing requires sample preparation (Category I, II, or III classification of each material type), acid extraction per the standard methodology, and analysis of all 19 elements by ICP-OES/ICP-MS. Allow 3–6 weeks for BS EN 71-3 results from most accredited labs.

07

Document UK REACH Article 33 SVHC communication. For any article you supply to other businesses that contains a UK SVHC above 0.1% concentration by weight, you must: notify the SVHC presence to your business customers automatically (not just on request); provide SVHC information to consumers within 45 days of request. Establish a process for receiving and responding to SVHC information requests, particularly for consumer-facing products.

08

Compile the chemical compliance dossier for the UK Declaration of Conformity supporting documentation. Include: material declarations, XRF screening reports, wet chemical test reports, SVHC assessment records, and compliance conclusions against each applicable restriction. Retain for minimum 10 years from placing on market. Review annually or when supply chain materials change.

## Frequently asked questions

### Is UK RoHS the same as EU RoHS?

UK RoHS (SI 2012/3032 as amended by SI 2019/492) mirrors EU RoHS 2 (2011/65/EU as amended by (EU) 2015/863) as of the date of Brexit — it restricts the same 10 substances with the same maximum concentration values at the homogeneous material level. The restricted substances list and their limits (lead 0.1%, cadmium 0.01%, mercury 0.1%, hexavalent chromium 0.1%, PBB 0.1%, PBDE 0.1%, and the four phthalates at 0.1% each) are currently identical. However, UK RoHS and EU RoHS are now separate legal frameworks that may diverge over time: any future amendments to EU RoHS (new substance additions or limit changes) do not automatically apply in the UK, and vice versa. Manufacturers supplying both the UK and EU markets must track both frameworks independently.

### What chemical tests are required for toys sold in the UK?

Toys sold in the UK must comply with the Toys (Safety) Regulations 2011 (SI 2011/1881), which incorporate BS EN 71 toy safety standards by reference. Chemical testing requirements include: BS EN 71-3 (migration of heavy metals — 19 elements tested per material category), BS EN 71-9 (organic chemical compounds — migration of restricted substances from toy materials into saliva/sweat simulants), and potentially BS EN 71-12 (N-nitrosamines and N-nitrosatable substances in rubber toys). For toys intended for children under 3 years with plastic or rubber components, phthalate testing per UK REACH Annex XVII and BS EN 71-9 is typically required. PAH testing per UK REACH Annex XVII Entry 50 applies to rubber and soft plastic toy components with skin or oral contact. All tests must be conducted at UKAS-accredited laboratories.

### What is a UK REACH SVHC and when must you disclose it?

A UK REACH SVHC (Substance of Very High Concern) is a chemical substance placed on the UK REACH Candidate List published by HSE because it meets SVHC criteria — typically being carcinogenic, mutagenic, or toxic to reproduction (CMR), persistent bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB). Under UK REACH Article 33, if you supply articles to other businesses or to consumers containing a UK REACH SVHC above 0.1% by weight of the article, you must: proactively communicate SVHC information to business customers (automatically, not just on request); provide SVHC information to consumers within 45 days of their request. The 0.1% threshold applies to the article as a whole — not the homogeneous material level. Importers should check the UK REACH SVHC Candidate List at hse.gov.uk before placing products on the UK market.

### Can I use EU laboratory test reports for UK market compliance?

Yes, in most cases. Test reports from laboratories accredited to ISO/IEC 17025 by an accreditation body that is a member of the ILAC (International Laboratory Accreditation Cooperation) mutual recognition arrangement are generally accepted for UK market compliance. EU-accredited laboratories (accredited by DAkkS in Germany, COFRAC in France, ACCREDIA in Italy, etc.) can produce test reports accepted for UK conformity. The UK's UKAS is an ILAC member, so UKAS-accredited labs produce reports accepted across ILAC member markets. However, specific UK regulations may specify that tests must be from UKAS-accredited labs — check the applicable UK legislation. For UK toy safety (BS EN 71 testing), UKAS accreditation for the specific toy safety test methods is strongly preferred and expected by UK Trading Standards.

**Disclaimer:** Educational resource only. Regulatory requirements change. Consult a qualified compliance specialist before making decisions.

🇬🇧 UK roadmap for your product

Every standard, document, and test that applies — free, no account required.

See your free roadmap

Learn this properly

In-depth course that teaches the full process, not just this one answer.

[Start the course — $149](/courses/15-uk-reach-rohs-chemical-compliance-post-brexit)[Prefer to read? Get the book — $24.99](/books/15-uk-reach-rohs-chemical-compliance-post-brexit)

Related guides

*   [UK RoHS ComplianceComplete guide to UK RoHS regulations: restricted substances, exemptions, compliance documentation, and UKCA marking requiremen…](/guides/uk-rohs-compliance)
*   [UK REACH ChemicalsComplete guide to UK REACH: substance registration, restrictions, authorisation, and compliance obligations for chemicals place…](/guides/uk-reach-chemicals)
*   [UK REACH HSEUK REACH registration with HSE: grandfathered UKREACH registrations, substance evaluation, restriction proposals, and differences from EU REACH post-Brexit.](/guides/uk-reach-hse-registration)
*   [UK Toy Safety RegulationsComplete guide to UK Toys (Safety) Regulations: essential safety requirements, chemical restrictions, conformity assessment, an…](/guides/uk-toys-safety)
*   [EU RoHS 10 Restricted Substances and LimitsEU RoHS 2011/65/EU as amended by (EU) 2015/863: all ten restricted substances with their maximum concentration values, the homogeneous material rule, Annex III and IV exemptions including lead solder, and IEC 62321 test methods.](/guides/eu-rohs-10-substances-limits)