Two different regulatory regimes with two different restricted-substance lists.
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) governs any product entering the EU market, restricting or requiring authorisation for substances of very high concern — phthalates, certain flame retardants, and heavy metals among them. CPSIA is the US equivalent for children's products specifically, mandating third-party lab testing by a CPSC-accepted facility before a product can legally enter the US market for anyone under 12.
The compliance gap most buyers underestimate isn't the testing itself — it's that both frameworks are periodically updated, and a formulation compliant last year isn't guaranteed compliant this year. REACH's restricted substance list (Annex XVII) and its Substances of Very High Concern candidate list both get revised on an ongoing basis; a component supplier several tiers removed from the final product may not even know their material is now flagged.
That's precisely the blind spot independent lab testing exists to catch. A finished-goods inspection checking for functional and cosmetic defects will not catch a restricted substance in an internal component — that requires targeted chemical testing, on a schedule tied to the regulation's own update cycle, not a one-time check at product launch.
Want the monthly version of insights like this? Subscribe to the QIV Insight.