REACH & RoHS for black masterbatch exports: a buyer's compliance checklist
The risk in exporting black masterbatch to the EU is rarely the masterbatch itself — it is undocumented supply. A shipment held at customs because the material passport is thin costs more than the product. Here is what to keep in your vendor file.
1. REACH — registration and SVHC
REACH requires substances of very high concern (SVHC) above 0.1% to be declared. For a standard carbon-black masterbatch, the main watch-items are additives and any restricted substances in the formulation, not the carbon black itself. Ask your plant for:
- A REACH declaration / statement of compliance for the grade.
- SVHC screening above the 0.1% threshold, if applicable.
- Confirmation the imported substance is covered (or exempt) under the EU framework.
2. RoHS — restricted substances for E&E
If the masterbatch ends up in electrical and electronic equipment (connectors, housings, cabling), RoHS restricted substances (lead, cadmium, mercury, etc.) apply. State the end-use up front so the plant can confirm the grade is RoHS-aligned. Our automotive and electronics grades are specified with this in mind.
3. Food-contact film — EU 10/2011 and FDA
For films that touch food (packaging, agricultural film that may contact produce), the relevant rules are EU 10/2011 (and its positive lists) or FDA expectations for the US. This means:
- A carrier and additive package on the positive list for food contact.
- Documented compliance, not just a verbal "it's fine."
- A grade formulated for the specific contact condition (temperature, fat content).
4. The material passport
Keep a small compliance folder per grade: REACH statement, RoHS confirmation (if E&E), food-contact docs (if applicable), and lot certificates. This is what customs and your own QA will ask for, and a certified plant is built to produce it. See our certifications page for the systems we run (ISO 9001 / IATF 16949 / ISO 14001).
5. A buyer's compliance checklist
- State the end-use (automotive / film / pipe / E&E / food-contact) on the inquiry.
- Request REACH + SVHC declaration with the quote.
- Request RoHS confirmation if the part is electrical/electronic.
- Request food-contact docs if the film touches food.
- Keep lot certificates in your vendor file for traceability.
6. Why plant certification helps
Plants that already run IATF 16949 and ISO 14001 tend to have the document discipline to support compliance out of the box. Buying factory-direct means the compliance paper comes from the maker, not filtered through a reseller who may not hold the original records. For common questions, see our FAQ.