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Our custom card printing line passed REACH testing against 253 SVHCs (ECHA candidate list, 4 February 2026). See exactly what we tested, why a self-declaration letter fails, and how this protects your EU-bound card game shipment.
If you have ever asked a supplier “Are your cards REACH compliant?” and they handed you a one-page letter saying “We confirm our products comply with all applicable regulations” — congratulations, you have been given a piece of paper that proves exactly nothing.
REACH compliance does not come from a Word document. It comes from a laboratory. And in our case, it comes with a dated test report showing exactly how many substances we screened against, and what the conclusion was. Spoiler: 253 substances. Result: PASS.
Figure 1 — Thriwa finished-product REACH test report, dated 26 August 2026.We sent actual production samples to a third-party testing laboratory. Here is the precise scope, copied directly from the test request — no paraphrasing:
| Item | Detail |
|---|---|
| Regulation | REACH (EC) No. 1907/2006 |
| Screening scope | Candidate List of Substances of Very High Concern (SVHC) |
| List version | Per ECHA publication dated 4 February 2026 |
| Number of SVHCs screened | 253 |
| Threshold | 0.1% (w/w) per substance in the sample |
| Result | PASS — all 253 substances below the 0.1% threshold |
Let that sink in for a second. We did not test “some relevant chemicals.” We tested every single substance on the official ECHA candidate list as it stood on the date of testing — 253 of them — on finished card samples. All below the legal limit.
The SVHC candidate list is a moving target. ECHA updates it roughly every six months, and the count climbs each time. A supplier who tested in 2021 against ~210 substances cannot honestly claim compliance today without re-screening.
That is why the date on the report matters more than the number:
So when we say “REACH compliant,” we can tell you exactly which list version that statement is anchored to. Most suppliers cannot.
REACH — Registration, Evaluation, Authorisation and Restriction of Chemicals — is the EU’s core chemical safety regulation, and it applies to every product entering the European market, not just toys.
For printed paper products like cards, there are two parts that matter:
Per Article 33 of REACH, if any SVHC is present above 0.1% w/w in your product, you are legally required to:
Our result: none of the 253 SVHCs exceeded 0.1% w/w. PASS.
This is separate from SVHC and covers substances that are flat-out prohibited above legal limits. For card printing, the main risk points:
| Substance / Group | Where it hides |
|---|---|
| Phthalates (DEHP, DBP, BBP, DINP…) | Lamination film, PVC coatings, soft-touch varnish |
| Azo dyes | Colored inks — can release carcinogenic amines |
| PAHs | Carbon black in inks, recycled filler, solvent coatings |
| Formaldehyde | Tuck box adhesive, wet-strength coating |
| Heavy metal compounds | Pigment inks, metallic finishes |
We address Annex XVII through our fixed, qualified material set — the same one that carried the SVHC screen to a clean pass.
Here is the uncomfortable truth: most suppliers claiming REACH compliance have never paid for a single test. They do one of three things:
| What they say | What they actually have |
|---|---|
| “Our products are REACH compliant” | A self-declaration letter they typed themselves |
| “We have REACH certification” | An ink supplier’s MSDS (not a compliance test) |
| “No problem, fully compliant” | No lab name, no date, no scope — just confidence |
When Amazon EU asks for “REACH test evidence” during category approval, or when EU customs pulls a shipment for chemical screening, a self-declaration gets rejected in minutes.
A dated third-party report — naming the regulation, the list version, the threshold and the result — is what gets your goods released.
If you are selling cards into the EU — Amazon, Shopify, distributors, retail — here is your compliance position with us:
One honest caveat: because ECHA updates the candidate list periodically, a future shipment may need a fresh screen if new SVHC additions touch our material set. We monitor this actively and re-test when triggered — never silently relying on an outdated report.
REACH (EC) No 1907/2006 is the EU’s chemical safety regulation. For printed cards it means your product must stay below 0.1% w/w of any SVHC on the ECHA candidate list (Article 33) and must not contain Annex XVII banned substances above legal limits. Compliance is proven by a dated third-party lab report — not a supplier letter.
We screened finished card samples against 253 SVHCs from the ECHA candidate list version dated 4 February 2026, at the 0.1% w/w threshold. Result: PASS — all 253 below the limit.
No. Amazon EU category approval and EU customs chemical screening reject self-declaration letters within minutes. They require a dated third-party report naming the regulation, list version, threshold and result — which we provide on file.
REACH applies to every product entering the European market, not just toys. Tarot decks, flashcards, TCG cards, board-game components and promotional cards all fall under it.
Changing qualified materials — for example adding metallic foil, neon ink or a new laminate — triggers a re-screen. We flag this before proof approval, and we also re-test when a future ECHA update adds SVHCs that touch our material set. We never silently rely on an outdated report.
Yes. Send your brief to info@gzsanwa.com and we will tell you exactly where your specification stands against our 253-SVHC scope and Annex XVII controls.
REACH compliance isn't a document. It's a process that ends at a laboratory.
For us, that process produced a report with three numbers worth remembering:
If your card product is heading to Europe — tarot, flashcards, TCG, board game component — you now have a manufacturing partner who can hand you a dated, third-party test report when your platform, importer or customs asks for one. Not a promise. Not a template. Proof, with the list version printed on it.
Want to see how our REACH test scope maps to your specific deck specification? Send us your brief and we'll tell you exactly where you stand.
