Resin compliance documents: what to request and why

How resin compliance documents work

• They come from the producer, the only party that knows the full formulation. A distributor passes them along.
• They are grade-specific. A statement for "polycarbonate" in general, without your grade on it, will not satisfy an auditor. Color can matter too, because pigments are a common source of restricted substances.
• They are dated. Check that each one cites the current regulation or list version.
• They cover the resin as supplied. Masterbatch, additives, inserts and coatings need their own statements, and compliance of the finished article is the article maker's responsibility.

A COA is different: it reports test results for one lot, not regulatory status. See what a COA shows.

The documents at a glance

General guidance as of October 2026, not legal advice. Exact wording, scope and thresholds vary by producer, grade and regulation version. Check the current rule text for anything you sign.

RoHS

EU Directive 2011/65/EU, with Annex II as amended by Delegated Directive (EU) 2015/863, restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE and four phthalates (DEHP, BBP, DBP and DIBP). The limit is 0.1% by weight in each homogeneous material, except cadmium at 0.01%. "RoHS 3" is the informal name for the ten-substance list.

Base polymers seldom contain any of these. The risk sits in additives: older lead or cadmium pigments, legacy brominated flame retardants and phthalate plasticizers in flexible PVC.

REACH

Under EU REACH, resin pellets are a mixture and your molded part is an article. Article 33 says a supplier of an article containing a Candidate List substance of very high concern (SVHC) above 0.1% w/w must give recipients enough information for safe use, at least the substance name, and must answer a consumer request within 45 days. Since a 2015 EU Court of Justice ruling, the 0.1% applies to each component article in an assembled product.

The Candidate List passed 250 entries in June 2025 and had 253 after the February 2026 update, and ECHA adds substances about twice a year, so the producer's REACH statement should say which list date it was checked against.

California Prop 65

Prop 65 requires businesses with 10 or more employees to give a clear and reasonable warning before knowingly exposing people in California to a listed chemical, unless the exposure is below the safe harbor level. The list is maintained by OEHHA and updated at least once a year. Revised short-form warnings, which name at least one chemical, apply to products made or labeled from January 1, 2028.

A resin Prop 65 statement lists the chemicals the producer knows are present, such as bisphenol A in polycarbonate, residual styrene in polystyrene and ABS, or antimony trioxide in some flame-retardant grades. Whether the finished product needs a warning depends on exposure, which is the product maker's call.

TSCA and the PFAS reporting rule

A TSCA statement says every chemical substance in the grade is on the TSCA Inventory or exempt. U.S. importers of resin need this to make the TSCA compliance statement that U.S. Customs requires on imports.

The separate PFAS reporting rule under TSCA section 8(a)(7) is a one-time report from anyone who manufactured or imported PFAS, including PFAS in articles, in any year from 2011 through 2022. As of October 2026, EPA's April 2026 rule sets the submission period to open on January 31, 2027, or 60 days after EPA's revised rule takes effect if that comes first, and the window as currently codified runs six months (twelve for small businesses reporting only as article importers), which EPA has said a later rule may change. EPA proposed exemptions in November 2025, including imported articles and PFAS at 0.1% or less, but they were not final at the time of writing. Check EPA's rule page before you rely on any date.

PFAS-free statements

Customers ask for these even where no law applies. Definitions differ: some state laws count any substance with a fully fluorinated carbon atom, which includes PTFE, while EPA's reporting rule uses a narrower structural definition. A useful statement names its definition and says whether it rests on formulation ("not intentionally added") or testing. PTFE-lubricated wear grades and flame-retardant grades with a PTFE anti-drip agent are where PFAS usually turns up. See PFAS-free alternatives for molding resins.

FDA food contact and UL

A food-contact letter cites the 21 CFR section or FCN and the conditions of use it covers. What to ask for and how to read it is on our FDA food-contact page. For flame and electrical parts, the UL yellow card lists the rating by thickness and color; look the grade up in UL's directory and see UL 94 ratings explained.

Halogen-free

Many electronics customers borrow the IEC 61249-2-21 definition, written for circuit board laminates: no more than 900 ppm chlorine, 900 ppm bromine and 1,500 ppm of the two combined. PVC and brominated flame-retardant grades will not meet it. Fluorine is not counted, so a halogen-free grade can still contain PTFE.

Heavy metals in packaging

U.S. toxics-in-packaging laws based on the CONEG model, now maintained by the Toxics in Packaging Clearinghouse, ban intentionally added lead, cadmium, mercury and hexavalent chromium in packaging and cap the incidental total at 100 ppm. The 2021 model adds PFAS and ortho-phthalates, but each state decides what it adopts. The EU Packaging and Packaging Waste Regulation, applying from August 12, 2026, keeps the same 100 mg/kg total. Expect this request on closures, containers and trays.

Conflict minerals and country of origin

The CMRT covers tin, tantalum, tungsten and gold for companies reporting to the SEC. Resins rarely contain them; a few tin-based stabilizers and catalysts are the exceptions. Producers commonly reply with a statement that none are intentionally added. Mica-filled grades can draw an EMRT request, because natural mica is in its scope.

Country of origin is where the resin was polymerized or compounded, which matters for tariffs and trade-agreement duty claims. The resin's origin does not by itself decide the origin of your molded part.

A request you can send your supplier

Subject: Compliance documents for [grade name, color]

Hello,

For the grade below, please send the producer's current documents:

Grade and color: [exact grade name and color code]
Our PO or quote number: [number]
End market: [EU / California / U.S. / Canada; food contact yes/no]

1. RoHS statement (2011/65/EU as amended by 2015/863)
2. REACH SVHC statement, with the Candidate List date checked
3. California Prop 65 statement
4. TSCA statement and PFAS statement (intentionally added, and the definition used)
5. [If needed] FDA food-contact letter for: [food type, temperature]
6. [If needed] UL yellow card or file number for our thickness and color
7. [If needed] Halogen-free and toxics-in-packaging statements
8. Country of origin and current SDS

Please make sure each document names the grade and is dated.

Thank you,
[Name, company, phone]

When the documents come back, check that each names your exact grade and color, is on the producer's letterhead, is dated, cites the current rule and has conditions (food type, temperature, thickness) that cover your part. File them with the part record and the lot COAs; our incoming inspection guide covers the dock side.

How we can help

Every lot ships with a COA. Tell us which compliance documents your customer needs when you ask for a quote, and a polymer chemist will confirm what the producer provides for that grade before you order. We forward the producer's documents for the grade we supply. Orders start at one gaylord, and standard terms are FOB the warehouse. We aim to send your quote within one to three business days.

Common questions