REACH Compliance for Chemical Buyers: What You Need to Know
Navigating the EU's REACH regulation can be complex. This guide breaks down the key obligations for buyers importing chemicals into Europe.
REACH — Registration, Evaluation, Authorisation and Restriction of Chemicals — is the EU's primary chemical regulation, and its reach (no pun intended) extends far beyond European borders. If you buy chemicals from a non-EU supplier for use in Europe, or if you manufacture and export chemical-containing products into the EU, REACH obligations likely apply to you.
The Core Principle: No Data, No Market
REACH places the burden of proof on industry, not regulators. Chemical manufacturers and importers must register substances with the European Chemicals Agency (ECHA) before placing them on the EU market, providing data on hazardous properties and how risks are managed. Substances that have not been registered cannot be manufactured or imported in the EU above threshold volumes.
Who Does REACH Apply To?
- EU manufacturers: Any company manufacturing chemicals in the EU
- EU importers: Companies importing chemicals (as substances, in mixtures, or in articles) into the EU
- Only Representatives (OR): Non-EU manufacturers can appoint an EU-based OR to take on REACH obligations on their behalf
- Downstream users: Companies using chemicals in their industrial or professional activities — they have narrower obligations but still must communicate in the supply chain
Registration Thresholds
REACH registration is volume-triggered. Thresholds are per substance per registrant per year:
| Volume (tonnes/year) | Registration Tier |
|---|---|
| < 1 tonne | No registration required (some notification requirements) |
| 1–10 tonnes | Registration required with minimum data set |
| 10–100 tonnes | Registration with expanded physical-chemical and ecotox data |
| 100–1,000 tonnes | Full registration including extended safety study data |
| > 1,000 tonnes | Highest data requirements including PBT/vPvB assessment |
SVHC: Substances of Very High Concern
ECHA maintains a Candidate List of SVHCs — substances with particularly concerning properties (carcinogenic, mutagenic, reproductive toxicity, PBT, vPvB, or endocrine disruptors). If your product contains an SVHC above 0.1% by weight, you have two main obligations:
- Notify ECHA if you supply articles containing SVHCs above threshold (via SCIP database)
- Inform your customers about the presence of the substance and how to use the article safely
- Respond within 45 days if a consumer asks whether your product contains an SVHC
The Authorisation Requirement
SVHCs can be added to the Authorisation List (Annex XIV). Once listed, the substance cannot be used or placed on the EU market after a 'sunset date' unless the specific use has been authorised by ECHA. This affects industries using certain phthalates, hexavalent chromium compounds, and brominated flame retardants, among others.
Practical Steps for Chemical Buyers
- Ask suppliers for REACH registration numbers for any substance you import above 1 tonne/year
- Request current SDS that reference REACH compliance — the SDS format itself is REACH-mandated (16-section format per Regulation 453/2010)
- Check the ECHA Candidate List regularly — SVHCs are added multiple times per year
- For articles: map which substances in your supply chain could be present above 0.1% in any article
- Keep documentation: REACH requires supply chain communication records to be maintained
Post-Brexit: UK REACH
Since Brexit, Great Britain has its own REACH regime (UK REACH), administered by the Health and Safety Executive (HSE). EU REACH registrations are not automatically valid in the UK. If you supply both EU and UK markets, you may need separate registrations. Northern Ireland continues to follow EU REACH under the Windsor Framework.
Chemizon Editorial
Published on May 15, 2026