REACH and RoHS dominate the compliance conversation, and two other screens are missed often enough to cause rejected containers. The first is PAHs, the polycyclic aromatic hydrocarbons that live in extender oils, carbon black and some recycled streams. The second is California Prop 65, a warning-label law with no general concentration limit, which means a part can pass every EU test and still carry a warning obligation in California. Both are buyer-side declarations, and both are cheap to ask for before the order.
PAHs: where they actually hide
PAHs are combustion by-products, and they enter plastic parts through the supply chain rather than the polymerisation. Extender oils used to soften rubber and soft PVC compounds can carry PAH loads. Carbon black, used in every black masterbatch and every black rubber part, varies in PAH content by source, and a black grip from one carbon black is not the same declaration as the same grip from another. Recycled streams can concentrate them. The parts that trigger questions are the soft and the black: grips, tyres, cable jackets, shoe soles, and any dark flexible part that spends its life against skin.
| Screen | Applies to | Typical trigger | What to ask for |
|---|---|---|---|
| PAHs | Soft and black parts, skin contact | Extender oils, carbon black source | Test report per material family, AfPS or EN method |
| Prop 65 | Anything sold into California | Listed chemical above safe harbour level | Exposure assessment or warning plan |
| Phthalates | Soft PVC, toys, food contact | Plasticiser selection | Plasticiser declaration per grade |
The PAHs test that matters
The German AfPS GS 2014 scheme and the EN standards behind it test for the eight REACH-regulated PAHs in materials with prolonged skin contact, and the limits are stated per individual PAH in milligrams per kilogram of material. What buyers should insist on is a test per material family, not per finished product: a programme with six parts in three materials needs three declarations, and a declaration that covers the whole catalogue is a declaration that covers nothing. The carbon black source is the question that resolves most black-part cases, and a supplier who can name the carbon black supplier can usually produce the test.
Prop 65: a warning law, not a limit law
California Prop 65 works differently from every regulation buyers know from Europe. The state publishes a list of more than nine hundred chemicals, and a business must warn consumers before knowingly exposing them to a listed chemical, unless the exposure is below a stated safe harbour level. There is no general pass or fail concentration, the safe harbour levels are per chemical and in some cases absurdly low, and enforcement is largely driven by private plaintiffs who send notices to sellers rather than regulators. For a plastic parts buyer, the practical consequence is that a part containing a listed substance, phthalates, lead, certain PAHs, needs either an exposure assessment showing the safe harbour is met or a warning plan on the packaging.
What to do before the order
Three actions close most of the exposure. First, ask for declarations per material family covering PAHs and the Prop 65 list, before tooling rather than after the container is at the port. Second, for black and soft parts, ask which carbon black and which extender oil, because those two answers determine the test result. Third, decide the warning question commercially: whether the California market justifies an exposure assessment, or whether the part ships with a warning label, is a pricing decision the buyer should make with the numbers in hand rather than discover through a notice letter.
Related reading
The phthalate and heavy metal limits in toys covers the adjacent soft-PVC screen, and the REACH, RoHS and food contact declaration guide covers the documents an export file needs.
Related product categories
The materials and part types discussed above are grouped in our sourcing directory:
