What is REACH and why does it matter for my products?

REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is the EU's comprehensive chemical safety regulation. It matters because any product containing chemicals—which includes virtually all manufactured goods—must comply with REACH requirements to be legally sold in the EU. Non-compliance can result in products being removed from the market, fines, and legal liability.

Do I need to register my products under REACH?

Registration requirements depend on your role. If you're a manufacturer or importer of chemical substances into the EU in quantities of 1 tonne or more per year, you must register with ECHA. If you're an importer of finished products (articles), you generally don't need to register unless your articles intentionally release substances or contain SVHCs above 0.1% that aren't already registered for that use.

What are SVHCs and why are they important?

SVHCs (Substances of Very High Concern) are chemicals identified as having serious hazardous properties—carcinogenic, mutagenic, toxic to reproduction, persistent in the environment, or endocrine disrupting. If your product contains SVHCs above 0.1% by weight, you have specific communication and notification obligations under REACH Article 33 and Article 7.

How do I know if my product contains restricted substances?

Request a REACH compliance declaration from your supplier that confirms the product meets REACH requirements, including Annex XVII restrictions. For SVHCs, ask for a declaration stating whether any Candidate List substances are present above 0.1%. You may also need laboratory testing for verification, especially for high-risk product categories or suppliers.

What is the SCIP database and do I need to submit information?

SCIP (Substances of Concern In articles as such or in complex objects/Products) is an EU database where companies must notify articles containing SVHCs above 0.1%. If you place articles on the EU market containing Candidate List substances above this threshold, you must submit a SCIP notification to ECHA. This applies to manufacturers, importers, and EU-based distributors who supply to consumers.

What happens if my product doesn't comply with REACH?

Non-compliance can result in market surveillance action including product recalls, import refusals, and fines. Penalties vary by member state but can reach millions of euros for serious violations. Online marketplaces like Amazon also enforce REACH and may suspend listings or require compliance documentation.

Do I need a Safety Data Sheet for my product?

Safety Data Sheets (SDS) are required for chemical substances and mixtures that are hazardous, or that contain SVHCs above certain thresholds. For finished articles like electronics or clothing, an SDS is generally not required unless the article releases hazardous substances. However, you must still be able to provide safety information and SVHC declarations upon request.

How does REACH interact with other EU regulations like CE marking?

REACH works alongside other EU product regulations. Products requiring CE marking must also comply with REACH—the chemical safety requirements are additional to directive-specific requirements. For example, an electronic device needs both CE marking (under LVD/EMC) and REACH compliance for any chemicals in plastics, coatings, or components.

What is the REACH Candidate List and how often is it updated?

The Candidate List is ECHA's list of SVHCs identified for eventual inclusion in the Authorization List. It's updated twice yearly (usually January and July) and currently contains over 230 substances. You must monitor updates as new additions trigger immediate communication and notification obligations for products already on the market.

As a non-EU seller, what are my REACH obligations?

Non-EU manufacturers cannot directly fulfill REACH obligations—you need an EU-based entity. For substance/mixture imports, appoint an Only Representative (OR) to handle registration. For articles, your EU importer or authorized representative assumes compliance responsibility. Under GPSR, you also need an EU Responsible Person who can provide REACH compliance information.

EU Regulation

Chemical Safety

22 min read

REACH Compliance Guide

REACH is the EU's cornerstone regulation for chemical safety, affecting virtually every product sold in Europe. This comprehensive guide explains your obligations for substance registration, SVHC communication, restriction compliance, and SCIP database notifications—written for e-commerce sellers and product importers.

What is REACH?

REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is EU Regulation 1907/2006—the world's most comprehensive chemical safety legislation. It entered into force in 2007 and fundamentally shifted responsibility for chemical safety from public authorities to industry.

Under REACH, companies must identify and manage risks linked to the substances they manufacture and market in the EU. The regulation covers substances on their own, in mixtures, and in articles. This means virtually every manufactured product—from electronics to textiles to toys—must comply with REACH requirements.

The European Chemicals Agency (ECHA) manages the technical, scientific, and administrative aspects of REACH, including the registration database, Candidate List of SVHCs, and SCIP database. REACH is enforced at the member state level through market surveillance authorities.

For e-commerce sellers, REACH compliance is critical because online marketplaces and customs authorities increasingly check products for restricted substances. Products containing banned chemicals can be seized at borders, removed from platforms, or recalled—with significant financial and reputational consequences.

Key REACH Components

Registration

Manufacturers and importers must register substances produced or imported above 1 tonne/year with ECHA. Registration requires detailed safety data and is mandatory before placing substances on the market.

Evaluation

ECHA and member states evaluate registration dossiers and may request additional information. Evaluation checks compliance and investigates substances of potential concern.

Authorization

The most hazardous substances (SVHCs) require authorization for specific uses. Companies must apply for authorization and demonstrate risks are controlled or socioeconomic benefits outweigh risks.

Restriction

Annex XVII lists substances restricted or banned in certain products. Restrictions apply to all companies regardless of size or role—compliance is mandatory for market access.

Obligations by Supply Chain Role

EU Manufacturers

Register substances manufactured above 1 tonne/year with ECHA
Prepare and submit registration dossiers
Communicate safety information down the supply chain
Apply risk management measures identified in safety assessments
Update registrations when new information becomes available

EU Importers

Register imported substances above 1 tonne/year
Verify articles comply with REACH restrictions
Notify ECHA of SVHCs in articles (if applicable)
Submit SCIP notifications for articles with SVHCs
Ensure Safety Data Sheets accompany hazardous substances

Article Suppliers

Inform customers if articles contain SVHCs above 0.1%
Provide sufficient information for safe use
Submit SCIP database notifications
Respond to consumer SVHC inquiries within 45 days
Ensure compliance with Annex XVII restrictions

Only Representatives

Fulfill registration obligations on behalf of non-EU manufacturers
Keep substance import quantities up to date
Maintain and make available registration information
Communicate with ECHA on behalf of non-EU companies
Ensure downstream users have necessary safety information

Substances of Very High Concern (SVHCs)

SVHCs are chemicals with serious, often irreversible effects on human health or the environment. ECHA maintains the Candidate List of SVHCs, which currently contains over 230 substances. When an SVHC is present above 0.1% weight by weight in an article, specific obligations apply.

CMR Substances

Carcinogenic, Mutagenic, or toxic to Reproduction

Certain phthalatesLead compoundsCadmium compoundsChromium VI

PBT Substances

Persistent, Bioaccumulative, and Toxic

Certain flame retardantsPFAS compoundsChlorinated paraffins

vPvB Substances

Very Persistent and very Bioaccumulative

D4/D5 siloxanesCertain UV stabilizersMusk compounds

Endocrine Disruptors

Substances disrupting hormonal systems

Bisphenol ACertain parabensSome pesticides

Article 33 Obligation: If your article contains an SVHC above 0.1%, you must inform your customers with at least the substance name. Consumers can also request this information and you must respond within 45 days, free of charge.

Key Annex XVII Restrictions for Consumer Products

Annex XVII contains restrictions on the manufacture, placing on the market, and use of certain dangerous substances. These restrictions apply to all products regardless of origin—compliance is mandatory for EU market access. Here are the most relevant restrictions for consumer products:

Entry 23 - Cadmium

Prohibited in plastics, paints, and certain metal products

0.01% by weight in plastics

Products: Jewelry, toys, electrical equipment housings

Entry 27 - Nickel

Limited release from prolonged skin contact items

0.5 μg/cm²/week release rate

Products: Jewelry, watches, buttons, zippers, mobile phones

Entry 47 - Chromium VI

Prohibited in leather articles in contact with skin

3 mg/kg in leather

Products: Shoes, gloves, watch straps, bags, furniture

Entry 50 - PAHs

Limited in rubber/plastic parts with prolonged skin contact

1 mg/kg for individual PAHs

Products: Tool handles, toys, sports equipment, clothing

Entry 51 - Phthalates

Prohibited in toys and childcare articles

0.1% individually or combined

Products: Toys, teethers, childcare articles

Entry 63 - Lead

Prohibited in articles accessible to children and jewelry

0.05% by weight

Products: Jewelry, toys, zippers, buttons

SCIP Database Notifications

The SCIP database (Substances of Concern In articles as such or in complex objects/Products) requires companies to notify articles containing Candidate List substances above 0.1%. This obligation has been mandatory since January 2021 and applies to manufacturers, importers, and distributors supplying articles to the EU market.

Who Must Notify?

EU producers and assemblers of articles
EU importers of articles
EU distributors of articles (professional users exempt)
Companies placing articles on the EU market

Information Required

Article identification (name, identifiers)
SVHC name, CAS number, EC number
Concentration range of SVHC
Location of SVHC in the article
Safe use instructions

6-Step REACH Compliance Process

Identify Your Role

Determine your position in the supply chain—manufacturer, importer, downstream user, or article supplier—as this defines your specific REACH obligations.

Clarify if you manufacture, import, or distribute
Identify substances and articles in your portfolio
Determine annual quantities for substances
Check if you need an Only Representative

Map Your Substances

Create an inventory of all chemical substances in your products, including those in mixtures and articles.

Request full material declarations from suppliers
Identify all intentionally added substances
Document substances likely to be released from articles
Track quantities per substance per year

Check SVHC Status

Screen all substances against the Candidate List to identify SVHCs requiring notification and communication.

Compare inventory against current Candidate List
Calculate SVHC concentration by article weight
Document findings for each product
Set up monitoring for Candidate List updates

Verify Annex XVII Compliance

Ensure products comply with all applicable restrictions on substances in Annex XVII.

Identify applicable restriction entries
Obtain test reports for restricted substances
Verify supplier declarations against restrictions
Document compliance evidence

Establish Communication

Set up supply chain communication systems for safety information and SVHC declarations.

Obtain Safety Data Sheets for hazardous substances
Create SVHC declaration templates
Establish process for consumer inquiries
Document all communications

Submit Required Notifications

File SCIP notifications and any other required notifications with ECHA.

Prepare SCIP notification data
Submit via ECHA's SCIP database
Update notifications for new products
Maintain notification records

Common REACH Compliance Mistakes

Assuming finished articles don't need REACH compliance

Consequence: Articles containing restricted or SVHC substances can violate REACH

Solution: Verify all products against Annex XVII restrictions and SVHC requirements

Not monitoring Candidate List updates

Consequence: New SVHCs trigger immediate obligations for products already on market

Solution: Subscribe to ECHA updates and review products against each update

Relying on supplier declarations without verification

Consequence: False declarations leave you liable for non-compliance

Solution: Verify critical products with third-party testing, especially high-risk suppliers

Ignoring SCIP notification requirements

Consequence: Failure to notify is a violation even if SVHC presence is declared to customers

Solution: Submit SCIP notifications for all articles with SVHCs above 0.1%

Confusing registration with restriction compliance

Consequence: A registered substance can still be restricted in certain uses

Solution: Check both registration status AND Annex XVII restrictions for all substances

Frequently Asked Questions

Related Guides

CE Marking Complete Guide

REACH compliance is required alongside CE marking for EU market access.

RoHS Directive Guide

Related substance restrictions specifically for electronics and electrical equipment.

Unsure about REACH compliance for your products?

Use SellSafe to analyze your products against REACH requirements and get a clear action plan for chemical compliance in the EU market.

Check REACH Compliance