I know the anxiety that hits when a shipment arrives at a European port. You stare at your email, praying the customs officer doesn’t ask for a document you don’t have. It is a terrible feeling.
Yes, our Electrolytic Tin Plate (ETP) is fully REACH compliant for the European market. We source raw substrates from top mills like Baosteel and Shougang, ensuring all substances of very high concern (SVHC) are below the 0.1% threshold required by EU Regulation 1907/2006.
Compliance is more than just a piece of paper; it is the passport for your business. If your tinplate gets stuck at the border in Spain or Italy because of a missing chemical declaration, your production line stops. I want to help you avoid that nightmare. Below, I will break down exactly how we ensure our materials meet strict EU standards, so you can import with total confidence.
Do you have a valid REACH certificate for export to the EU?
I often talk to buyers who are frustrated by suppliers sending outdated certificates in Chinese. You cannot present a document to a European authority if they cannot read it or if it expired three years ago.
We provide a current, valid Declaration of Compliance (DoC) for every shipment. Since tinplate is classified as an "Article" under REACH, we certify that it does not release harmful substances under normal use, supported by Mill Test Certificates (MTC) from our premium steel sources.
Understanding the paperwork for European imports can feel like walking through a maze. It is crucial to know exactly what you are holding in your hand. Many buyers ask me for a "REACH Certificate," but in the strict legal sense of the regulations, there is a specific way this works for steel products.
Because Electrolytic Tin Plate (ETP) is a solid metal product, the European Chemicals Agency 1 classifies it as an "Article," not a chemical substance or mixture. This distinction changes the rules. We do not provide a Safety Data Sheet 2 in the same way a paint supplier would. Instead, we provide an Article Information Sheet (AIS) and a Declaration of Compliance.
At Huajiang, we leverage our massive supply chain to your advantage. We hold over 100,000 tons of stock from Baosteel and Shougang. These are state-owned giants. They have dedicated teams that constantly update their compliance data against the ECHA candidate list 3. When you buy from us, you inherit that safety.
Here is a breakdown of the documents we provide versus what you might see elsewhere:
Document Types Explained
| Document Type | What it is | Why you need it for ETP |
|---|---|---|
| Declaration of Compliance (DoC) | A formal statement from Huajiang confirming the product meets REACH Regulation (EC) No 1907/2006. | This is your primary proof for customs and internal audits. |
| Mill Test Certificate 4 | A technical data sheet showing chemical composition (C, Mn, Si, etc.) and mechanical properties. | It proves the steel’s origin and quality grade (e.g., MR, SPCC). |
| Article Information Sheet (AIS) | A document similar to an SDS but designed for solid articles. | It confirms there are no hazardous substances intended to be released. |
| SVHC Test Report | A third-party lab report (usually SGS) testing for Substances of Very High Concern. | It provides scientific proof that restricted chemicals are below 0.1%. |
When you request a quote from me, I can include these draft documents immediately. You do not have to wait until the goods are on the water to check if they are compliant. We believe in showing our cards early. This transparency saves you time and protects your reputation with your own customers.
How do I verify that your passivation chemicals are SVHC-free?
You might worry that hidden chemicals on the surface of the tinplate could contaminate your food products. With the "banned list" changing every six months, keeping up is a full-time job.
We strictly monitor our passivation processes to ensure no Substances of Very High Concern (SVHC) exceed limits. While traditional 311 passivation uses hexavalent chromium, the final surface residue is extremely low, and we also offer Chromium-Free Passivation (CFPA) alternatives that are 100% future-proof.
The topic of passivation is the most technical and critical part of REACH compliance for tinplate. Let’s dig into this because it directly affects the long-term viability of your supply chain.
Passivation is a chemical treatment applied to the tinplate surface. It prevents the tin from oxidizing (turning yellow) during storage and improves the adhesion of lacquers. For decades, the industry standard has been "311 Passivation," which uses a solution containing Substances of Very High Concern 5 like hexavalent chromium (CrVI).
Under REACH, hexavalent chromium 6 is a restricted substance. However, there is a major difference between the chemical used in the factory and the finished product you receive.
1. The Process vs. The Product: During manufacturing, the chromium undergoes a chemical reaction. On the finished tinplate surface, the chromium exists primarily in a stable, trivalent state or as metallic chromium. The amount of hexavalent chromium remaining is microscopic.
2. The 0.1% Threshold: REACH requires notification if an SVHC (like CrVI) is present in the article at a concentration above 0.1% by weight. In tinplate, the passivation layer is nanometers thick. The total weight of the chromium compared to the weight of the steel sheet is tiny—far, far below 0.1%. Therefore, standard 311 passivated tinplate is legal to import into the EU today.
However, we know the regulations are tightening. The EU is moving toward a total ban on the use of CrVI. To support clients like you who want to be ahead of the curve, Huajiang has invested heavily in Chromium-Free Passivation Alternatives (CFPA).
We use advanced zirconium-titanium based treatments on specific production lines. These are completely free of chromium. If you are supplying a major European retailer that demands "Green Packaging," this is the solution you need.
Comparison of Passivation Methods
| Feature | 311 Passivation (Traditional) | Chromium-Free (CFPA) |
|---|---|---|
| Primary Chemical | Sodium Dichromate (CrVI) | Zirconium / Titanium |
| REACH Status | Compliant (Finished Article < 0.1% SVHC) | Compliant (No restricted substances) |
| Sulphur Resistance | Excellent (Standard for high-protein food) | Good (Requires specific lacquer matching) |
| Food Safety | FDA & EU Approved | FDA & EU Approved |
| Future Risk | High (Regulations tightening by 2027) | Low (Future-proof) |
We can help you choose. If you are packing dried goods or industrial sprays, standard passivation is cost-effective and safe. If you are packing baby food or selling to strict Nordic markets, we can switch you to CFPA. We have the technology to do both.
Can you provide a declaration of compliance for heavy metals?
The words "Lead," "Cadmium," and "Mercury" are terrifying for anyone in the food industry. You cannot afford a product recall because your packaging material failed a random heavy metal test.
Yes, we certify that our tinplate complies with EU Directive 94/62/EC on packaging waste. The sum of concentration levels of lead, cadmium, mercury, and hexavalent chromium is strictly controlled to be less than 100 ppm (parts per million).
Heavy metal compliance is actually separate from REACH, but they often get grouped together in the buyer’s mind. While REACH focuses on chemical risks during use, the EU Directive 94/62/EC 7 focuses on the environmental impact when the package becomes waste.
This directive is non-negotiable for entry into the EU. It mandates that the total weight of four specific heavy metals—Lead (Pb), Cadmium (Cd), Mercury (Hg), and Hexavalent Chromium (Cr6+)—must not exceed 100 ppm in the packaging material.
At Huajiang, we take this incredibly seriously. Our quality control starts before the steel is even melted. Since we source from top-tier mills like Baosteel, the base steel purity is exceptionally high. Cheap steel often contains "tramp elements" from scrap metal recycling, which can spike lead levels. We do not use that material.
Our testing process is rigorous:
1. Raw Material Screening: We review the ladle analysis from the steel mill for every coil.
2. Process Control: Our tinning lines use high-purity tin ingots (99.99% pure). We do not use recycled tin sludge that could be contaminated with lead.
3. Third-Party Verification: We send samples to SGS or Intertek regularly. These labs dissolve the steel and use Inductively Coupled Plasma 8 testing to detect metals at the part-per-billion level.
Typical Heavy Metal Test Results vs. EU Limits
| Metal | EU Limit (94/62/EC) | Huajiang Typical Result | Status |
|---|---|---|---|
| Lead (Pb) | – | < 10 ppm | Pass |
| Cadmium (Cd) | – | < 5 ppm | Pass |
| Mercury (Hg) | – | Not Detected | Pass |
| Chromium VI (Cr6+) | – | < 20 ppm | Pass |
| Total Sum | Max 100 ppm | < 40 ppm | Pass |
We also ensure our lacquers and coatings meet these standards. If you buy printed tinplate or finished ends from us, the inks and varnishes are also heavy-metal-free. This provides you with a "system safety" approach. You don’t have to worry that the steel is safe but the paint is toxic. We cover the whole package.
Will this certification help me clear customs in Spain or Italy?
Your goods arrive in Valencia or Genoa, and the clock starts ticking. Every day your container sits in the port waiting for clearance, you pay demurrage fees 9. You need paperwork that works instantly.
Absolutely. Our complete documentation package, including the REACH Statement, Mill Test Certificate, and Certificate of Origin, is designed to satisfy EU customs officers immediately. We have years of experience shipping to Southern Europe and know exactly what they check.
Clearing customs in the European Union requires precision. It is not enough to just "be" compliant; you have to "prove" compliance in the format the officers expect. I have seen containers stuck for weeks simply because a Certificate of Origin didn’t match the invoice number perfectly.
When we prepare a shipment for you, we act as your partner in logistics, not just a factory. We understand that Spain, Italy, and France are some of the biggest producers of canned food in the world. They are also very protective of their local industries and very strict on imports.
Here is how we structure our support to ensure you clear customs fast:
1. The "Golden Packet" of Documents
For every container, we email you a PDF packet before the ship arrives. We also courier the originals. This packet includes:
- Commercial Invoice & Packing List: Detailed down to the net weight of every coil.
- Mill Test Certificate (MTC): This is the DNA of the steel. It links the coil number on the physical tag to the chemical analysis. Customs officers look for this linkage.
- REACH Declaration (DoC): Signed and dated for the current year.
- Eur1 / Form A / CO: Depending on trade agreements, we provide the correct Certificate of Origin 10 to help you manage or reduce import duties.
2. Handling the "Importer" Responsibility
Under REACH, the legal responsibility technically falls on the EU Importer (that is you). However, you cannot fulfill this duty without data from the manufacturer (us). We bridge this gap. We provide you with the technical data you need to file your own internal reports if your local authorities ask.
3. Future-Proofing for 2027
The EU regulations are shifting. The authorization for using Hexavalent Chromium in the EU is set to expire properly around 2027. This means European manufacturers will have to stop using it. As an importer, you might face new questions then.
We are already preparing for this. By establishing a relationship with Huajiang now, you gain access to a supplier who is already transitioning to Chromium-Free technology. When the laws change, you won’t have to scramble to find a new factory. We will simply switch your specification code, and you keep running without interruption.
We handle the complexity so you can focus on making cans.
Conclusion
Navigating EU regulations is tough, but you don’t have to do it alone. With our inventory of 100,000 tons of compliant material and full documentation support, we ensure your supply chain stays safe and moving.
Would you like me to email you a sample REACH Declaration and a recent SGS report so you can review them with your quality team?
Footnotes
1. Official website of the agency managing EU chemical legislation. ↩︎
2. Standard format for communicating hazard information for chemical products. ↩︎
3. Regularly updated list of substances identified as hazardous by ECHA. ↩︎
4. Certified document detailing the chemical and physical properties of steel. ↩︎
5. Identification criteria for chemicals with serious health or environmental effects. ↩︎
6. Information on the health risks associated with chromium VI exposure. ↩︎
7. EU rules targeting the management and reduction of packaging waste. ↩︎
8. Analytical technique used for detecting trace metals and chemical elements. ↩︎
9. Explanation of charges incurred when cargo exceeds free time at ports. ↩︎
10. International trade document certifying the country where goods were manufactured. ↩︎
