HiSiaddi is an innovative foreign trade service provider driven by dual engines of technology transformation and foreign trade services, with a service system of "1+2+3+4=1" and access to original supplies of polyepoxysuccinic acid from multiple well-known manufacturers. With over ten years of market experience and technology transformation cooperation with manufacturers, HiSiaddi possesses rich experience in product compliance issues. The following is a compliance handling case of polyepoxysuccinic acid from HiSiaddi.
If you need consulting on PESA product compliance issues, please contact HiSiaddi customer service.
Headquartered in Düsseldorf Fine Chemical Industrial Park, North Rhine-Westphalia, Germany, WasserTech has 28 years of R&D and manufacturing experience in high-end municipal drinking water scale inhibitors, industrial closed circulating water and Rhine River basin sewage treatment chemicals. Its products are included in the access list of the German Federal Drinking Water Authority and EU Environmental Agency, with all finished chemicals complying with REACH, CLP, German drinking water additive DIN standards and OECD biodegradation specifications. The client long purchased original imported modified PESA.
Due to shrinking local European chemical production capacity and rising raw material prices, the client launched a domestic China raw material replacement project, planning annual procurement of 210 tons of modified PESA (divided into seawater dedicated, high-temperature circulating water and compound-dedicated grades).
The client independently contacted two domestic mid-to-high-end PESA manufacturers for sampling and stock preparation. Before loading the first batch of 62 tons of goods, four major compliance barriers emerged successively: original manufacturer SDS failed to comply with new EU regulations 2020/878, no SVHC high-concern substance screening reports were available, no EU UFI codes + PCN toxic substance center notifications were completed, and product labels failed CLP classification specifications. German importers notified that incomplete documents would result in customs detention of goods at Hamburg Port, heavy fines and forced return of shipments. The client temporarily suspended delivery and fully entrusted HiSiaddi’s foreign trade compliance team with rectification and full set of compliance document preparation.
Domestic manufacturers only provided old national standard MSDS with 12 sections, failing to prepare standardized 16-chapter SDS in accordance with REACH Annex II (EU2020/878) new regulations. Missing content included endocrine disruptor disclosure, nano-component description, exposure limit parameters and UFI code columns. Documents were only available in Simplified Chinese and basic English without German statutory FDS safety data sheets, leading to direct rejection of documents by German customs and client quality inspection departments.
The EU SVHC list was updated to 253 items in 2026. German importers require upstream suppliers to submit full SVHC testing reports for PESA issued by CNAS-accredited laboratories to complete ECHA supply chain information filing. Domestic manufacturers only provided factory physical and chemical COAs (solid content, molecular weight, pH) without screening for harmful impurities, unable to verify that heavy metals, residual monomers, plasticizers and other SVHC substances are below the legal limit of 0.1%, failing to meet basic EU import access conditions.
Since 2023, the EU has mandated that imported chemical compound raw materials must complete PCN notification at the EU Toxic Substance Center and carry a 16-digit unique UFI formulation code on products. Domestic manufacturers have never completed this compliance procedure and lack an EU local Only Representative (OR), preventing the client from finishing import filing in Germany and prohibiting raw material warehousing and production by local safety supervision departments.
Original domestic barrel labels only marked product name, net weight and manufacturer, lacking GHS hazard pictograms, signal words, hazard statements and protective statements. Component descriptions on labels conflicted with component data on SDS. Per Hamburg customs inspection rules, inconsistent labels lead to full-container detention and rectification, generating huge port storage and detention fees.
1. Cooperate with domestic CMA/CNAS compliant laboratories to recompile standardized 16-chapter SDS following REACH new Annex II rules based on measured component data of three PESA grades, supplementing missing content including endocrine attributes, monomer residues, storage and transportation protection and occupational exposure limits.
2. Simultaneously prepare dual German and English versions of FDS (German statutory safety data sheets) with all terminology following official German chemical industry vocabulary to avoid translation ambiguity, ensuring documents can be directly used for German customs clearance and downstream filing.
1. Coordinate third-party laboratories with EU recognized qualifications to sample three PESA grades (seawater modified, high-temperature acid-form, low-monomer compound-dedicated) and complete full-spectrum screening of 253 SVHC items. Actual testing confirms all high-concern substances are below the 0.1% control threshold.
2. Issue testing reports with dual CNAS and ILAC accreditations plus REACH compliance statements, assisting the client with ECHA supply chain information submission to complete the critical documentation link of the REACH compliance chain.
1. Cooperate with EU local compliance institutions to appoint an EU domestic Only Representative (OR) for the three PESA grades, and complete PCN notification at the EU Toxic Substance Center based on product formula information.
2. Apply for exclusive UFI codes for each of the three segmented grades, uniformly mark codes on Chapter 1 of new SDS and outer product packaging to meet dual inspection requirements of German safety supervision and customs, breaking warehousing and filing barriers in Germany.
1. Redesign German-English bilingual barrel outer labels in accordance with CLP classification rules, standardizing addition of GHS hazard pictograms, hazard warnings, emergency contact information, UFI codes and product CAS numbers.
2. Verify component content, concentration and product name information item by item across labels, SDS and customs invoices to achieve full data consistency of three documents, avoiding customs inspection and detention risks caused by inconsistent information.
1. Delivery after rectification completion: After review and approval of full compliance documents, the 62-ton full container of PESA was shipped from Shanghai Port to Hamburg, Germany, with one-time customs clearance without inspection or detention. Raw materials passed German drinking water raw material incoming inspection after warehousing, enabling smooth operation of three production lines.
2. Phased delivery of remaining orders: The remaining 148 tons were shipped in three quarterly batches aligned with the client’s quarterly production schedules. HiSiaddi retained full compliance document templates for subsequent shipments to directly reuse materials and drastically shorten document preparation cycles.
3. Highlighted cost advantages and long-term renewal: Comprehensive domestic procurement costs dropped by 32.8% compared with original German import sources. In the following year, WasserTech renewed the annual procurement framework for 265 tons of PESA, and fully entrusted HiSiaddi with exclusive handling of import compliance and model selection business for PASP and organic phosphonate series scale inhibitors.
1. Industry Compliance Pain Points: Most domestic PESA manufacturers are only familiar with national Chinese standards and fail to track dynamic updates of EU REACH/CLP regulations, only capable of providing basic factory inspection reports without supporting full sets of EU compliance documents. Restricted by strict EU regulations, incomplete compliance documents prevent goods from landing, representing the biggest bottleneck for cross-border procurement by overseas mid-to-high-end clients.
2. Core Service Value of HiSiaddi: Move beyond simple supply matching as a foreign trade service provider to form a full closed-loop compliance chain covering testing, registration, notification, labeling and customs documents, bridging compliance shortcomings of domestic manufacturers and helping European and American mid-to-high-end clients avoid losses including return shipments, fines and production shutdowns. Deeply bind high-quality end clients through full compliance services.
3. Mid-to-High-End Client Procurement Logic: Leading high-end European and American manufacturers prioritize full-chain compliance guarantees, with product pricing secondary to compliance. One-stop full compliance solution capacity is the core competitiveness to secure large annual long-term framework orders.
If you need consulting on PESA product compliance issues, please contact HiSiaddi customer service.
+86-13120989737 
info@hisiaddi.com 
English
