SHANGHAI HI SILICON TECHNOLOGY CO., LTD.
SHANGHAI HI SILICON TECHNOLOGY CO., LTD.

Hindered Amine Light Stabilizer HALS-2020: Compliance Case Addressing Excessive SVHC Substances & Missing Food Contact Certifications

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    As a new-type foreign trade service provider driven by dual engines of technology transformation and foreign trade services, HiSiaddi has established a "1+2+3+4=1" service system and can supply original factory materials of HALS-2020 hindered amine light stabilizers from multiple well-known brands. Boasting over a decade of market experience and technological transformation cooperation with manufacturers, HiSiaddi has rich expertise in resolving compliance issues for additive products. The following is a case of HiSiaddi handling compliance risks for HALS-2020.

    Please contact HiSiaddi customer service if you need consultation on compliance issues of HALS-2020.

    I. Customer Profile (Mid-to-High-End Positioning)

    Client: PackSafe GmbH, Germany (referred to as Company P) Core Business: Top European manufacturer of food-contact flexible packaging and high-transparency fresh-keeping films & infant food bags, supplying German supermarkets and Swiss organic food brands. Its products must strictly comply with EU regulations including EU 10/2011 (food contact materials), REACH, RoHS and the latest SVHC Substances of Very High Concern list.

    Procurement Requirements

    Bulk domestic HALS-2020 was purchased for anti-aging modification of food-grade films as a cost-saving replacement for previous BASF imported materials. Zero tolerance for compliance risks was stipulated; additives must be accompanied by complete EU compliance documents and food contact certifications, with no restricted substances listed under SVHC.

    Core Pain Points

    Upon initial procurement of domestic HALS-2020, the client encountered fragmented compliance documents, missing key certifications, non-compliant SVHC test results and technical documents inconsistent with EU standards. Goods were detained at German ports due to incomplete paperwork, facing risk of return shipment and substantial demurrage fees. The client urgently commissioned HiSiaddi to resolve the compliance crisis.

    II. Four Major Compliance Risks (Impacting Customs Clearance & End-Use Application)

    1. REACH Compliance Loopholes: Excessive SVHC Substances & Outdated Registration Documents

    Issue: The supplier’s SVHC 224-item test report was an outdated 2023 version that failed to cover six new restricted substances added between 2024 and 2025. Trace N-oxide derivatives (new monitored substances under updated REACH) were detected above threshold limits in product testing, violating EU REACH regulations. Risk Classification: Violation of high-concern substance rules leading to port detention and blocked customs clearance.

    2. Missing Food Contact Compliance: No EU 10/2011 Certifications for Food Packaging Applications

    Issue: The supplier only provided general industrial-grade COAs without EU food contact material certifications (EU 10/2011) or German LFGB certifications, failing to prove safe application of HALS-2020 in food-contact scenarios. Risk Classification: Rejection of finished products by end food brand customers, production suspension and liability for breach of contract compensation.

    3. Incomplete RoHS & Environmental Documentation: No Heavy Metal & Hazardous Substance Test Reports

    Issue: Missing RoHS 2.0 test reports covering 10 hazardous substances including lead, mercury and polybrominated diphenyl ethers; packaging lacked EU environmental compliance labels, violating EU environmental directives. Risk Classification: Ban on product sales across the EU and irreversible damage to brand reputation.

    4. Non-Standard Technical Documentation: Mismatched Format & Missing Information in MSDS & COA

    Issue: The supplier provided Chinese-only Material Safety Data Sheets (MSDS) without official English translations; COAs omitted EU-mandated technical parameters including CAS number, EINECS number, volatile matter and migration volume, with no official seals from EU-recognized third-party laboratories. Risk Classification: Customs document audit failure and mandatory return shipment of goods.

    III. HiSiaddi Compliance Resolution: Closed-Loop Four-Step Solution to Address Full-Process Risks

    HiSiaddi maintains a team of EU compliance specialists and food contact certification consultants fully familiar with full-chain compliance requirements for HALS additives exported to the EU, covering REACH, SVHC, EU 10/2011 and RoHS. A closed-loop solution of "document supplementation → product rectification → authoritative testing → compliant delivery" was developed to resolve Company P’s crisis.

    Step 1: Urgent Customs Coordination to Apply for Extended Inspection Period & Minimize Demurrage Losses

    HiSiaddi’s local German agent immediately coordinated with Hamburg Customs to submit a statement of facts and temporary compliance commitment, applying for a 7-day extension of the inspection period to avoid direct return shipment of goods. Simultaneously coordinate shipping lines to suspend return procedures and lock warehouse storage locations, cutting daily estimated losses of over 2,000 EUR.

    Step 2: Screen Compliant Manufacturers & Drive Product Formulation & Process Rectification

    Eliminate the original non-compliant supplier and shortlist two mid-to-high-end HALS-2020 manufacturers with complete EU compliance qualifications (Jiangsu Lusheng, Tianjin Lianlong) for thorough verification of REACH registrations, food contact certifications and SVHC testing credentials. Collaborate with factory technical teams to rectify product specifications:

    1. Upgrade high-vacuum devolatilization post-treatment processes to fully remove SVHC-restricted N-oxide derivatives, ensuring non-detection of all 230 SVHC listed substances.

    2. Adopt food-grade raw materials for production with strict control of heavy metals and impurities to meet EU 10/2011 food contact standards.

    Step 3: Authoritative Third-Party Testing & Full Set of English Compliance Documents with EU-Authorized Seals

    HiSiaddi coordinated SGS Germany to conduct full-item testing per the latest EU standards and issue official English reports covering four compliance dimensions:

    1. REACH Compliance: 2025-version SVHC 230-item test report (no restricted substances detected), REACH pre-registration documents and filing certificates for CAS No.70624-18-9 and EINECS number.

    2. Food Contact Compliance: Full migration test reports under EU 10/2011 and German LFGB certifications verifying safe use in food-contact films.

    3. RoHS Compliance: RoHS 2.0 10-hazardous-substance test reports with non-detection of heavy metals.

    4. Standardized Technical Documents: Rewrite English MSDS complying with EU CLP regulations and COAs marked with full technical parameters and SGS official seals; attach EU compliance labels and batch traceability codes to packaging.

    Step 4: Secondary Customs Audit & Compliant Delivery, Establish Long-Term Compliance Mechanisms

    HiSiaddi submitted the full set of English compliance documents, test reports and technical materials for secondary audit by Hamburg Customs, which was approved within one working day to release detained goods. Original and electronic copies of all compliance files were delivered to Company P’s facility for internal compliance filing. A long-term compliance tracking mechanism was established: regular updates on EU regulatory revisions (e.g. newly added SVHC substances) and annual compliance reviews to guarantee zero compliance risks for future batches.

    IV. Cooperation Outcomes: Zero Compliance Risks & Deep Long-Term Binding Partnership

    1. Crisis Fully Resolved: Goods cleared customs smoothly and entered production with no return shipment, fines or breach-of-contract compensation, recovering direct economic losses exceeding 150,000 EUR.

    2. Full Compliance Achieved: Domestic HALS-2020 with complete documentation fully meets EU REACH, EU 10/2011 and RoHS standards for high-end food-contact applications.

    3. Significant Cost Optimization: Recommended mid-to-high-end domestic HALS-2020 (Lusheng LS-2020H, Lianlong Uvinul 2020S) delivers performance equivalent to BASF with 28% lower procurement costs.

    4. Long-Term Exclusive Cooperation: Company P fully recognized HiSiaddi’s compliance service capacity, placing stable monthly orders of 6–10 tons of HALS-2020 and designating HiSiaddi as its exclusive compliant supplier. Subsequent procurement of UV absorbers, antioxidants and other supporting additives is fully channeled through HiSiaddi.

    5. Word-of-Mouth Expansion: Company P recommended HiSiaddi’s compliance service case to other European food packaging enterprises, generating three new mid-to-high-end clients for HiSiaddi.

    V. Core Value of This Case: Targeted Resolution of Mid-to-High-End Clients’ Compliance Demands

    1. Client Profile: Top German food packaging manufacturer with core demands for zero compliance risks, complete EU certifications and food contact safety, rather than low-cost raw materials, representing a typical mid-to-high-end compliance-sensitive buyer.

    2. Core Pain Points: Fragmented, EU-standard-mismatched compliance documents and missing key certifications for domestic additives, resulting in customs detention and production suspension.

    3. Core Strength of HiSiaddi: Mastery of EU regulations, integration of authoritative testing resources, driving factory compliance rectification and provision of full-chain compliance documentation, upgrading service positioning from a product seller to a full EU compliance solution provider.

    4. Nature of Service: Help mid-to-high-end clients mitigate compliance risks, cut procurement costs and stabilize supply chains, securing long-term trust through professional compliance capabilities and realizing partnership upgrading from one-off transactions to deep binding cooperation.

    Please contact HiSiaddi customer service if you need consultation on compliance issues of HALS-2020.


    References
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