REACH Regulation (EU Chemical Compliance)

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is an EU regulation, formally EC 1907/2006, adopted on 18 December 2006 and entering into force on 1 June 2007. REACH is enforced by the European Chemicals Agency (ECHA), headquartered in Helsinki, Finland.

REACH applies to virtually all chemical substances — whether used on their own, contained in a mixture, or present in a manufactured article (a finished product like a phone case, a garment, or a chair). Its core objective is to ensure that companies placing chemicals or chemical-containing products on the EU market identify and manage the risks associated with the substances they use.

Unlike RoHS, which restricts a fixed list of substances specifically in electrical and electronic equipment, REACH covers a much broader universe of products and an actively growing list of substances of concern.

The Four Pillars: R-E-A-C-H

Understanding the SVHC Candidate List

The part of REACH that most directly affects product importers, brands, and sourcing teams is the SVHC Candidate List — a continuously updated list of Substances of Very High Concern.

• As of ECHA's February 2026 update, the Candidate List contains 253 substances, following the addition of n-Hexane and Bisphenol AF (BPAF) and its salts. The list is updated on a rolling basis, typically two to three times per year.
• Substances are added based on properties such as carcinogenicity, mutagenicity, reproductive toxicity (CMR), persistence and bioaccumulation (PBT/vPvB), or endocrine-disrupting effects.
• Common SVHCs found in consumer goods include certain phthalates (e.g., DEHP, DBP), lead compounds, and specific flame retardants.

The 0.1% Threshold Rule

If any SVHC is present in a manufactured article at a concentration above 0.1% weight by weight (w/w) of that article — not the entire product assembly, but each individual "article" component — specific legal duties are triggered, even if the substance is not banned.

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Article 33: The Notification Duty Importers Often Miss

Article 33 of REACH creates a communication obligation that catches many importers off guard.

• Suppliers must inform: Any supplier of an article containing an SVHC above the 0.1% threshold must proactively inform their commercial customer (at minimum: the substance name).
• Consumers can request: Any consumer has the legal right to ask a company whether a product they purchased contains an SVHC above the threshold, and the company must respond within 45 calendar days, free of charge.
• This applies at every tier: A finished-goods importer is legally responsible for knowing whether their upstream component suppliers (e.g., a zipper manufacturer, a cable supplier) have SVHCs in their parts — even if the importer never handles raw chemicals directly.

REACH vs. RoHS: Key Differences

These two regulations are frequently confused because both concern restricted substances in the EU market. They are not interchangeable.

In practice, an electronics product sold in the EU typically needs to demonstrate compliance with both REACH and RoHS simultaneously — they are complementary, not substitutable.

How Importers Can Build a REACH Compliance Process

1. Map your Bill of Materials (BOM) down to the component and material level — REACH liability is assessed per "article," not per finished product.
2. Request Material Safety Data Sheets (MSDS/SDS) and SVHC declarations from every tier-1 and, where possible, tier-2 supplier.
3. Commission third-party lab testing for high-risk material categories (plastics, printed materials, metal plating, synthetic textiles) against the current SVHC Candidate List.
4. Monitor SVHC list updates twice yearly and re-screen existing product lines when new substances are added.
5. Retain documentation for at least 10 years after the substance was last supplied, as required under REACH record-keeping obligations.
6. Appoint an Only Representative (OR) if you are a non-EU manufacturer exporting without an EU-based legal entity, since REACH registration obligations fall on EU-established importers or their designated OR.

Penalties for Non-Compliance

Enforcement is handled at the EU member-state level, so penalties vary by country, but consequences commonly include:

• Market surveillance authorities can order products withdrawn or recalled from the EU market.
• Customs authorities may detain or seize shipments found to violate restriction limits.
• Fines in major markets (e.g., Germany, France) can reach tens of thousands of euros per violation, with repeat or willful violations escalating further.
• Reputational damage from public RAPEX (EU Safety Gate) alerts, which are searchable and frequently referenced by retailers and marketplaces like Amazon EU.

Why REACH Compliance Matters for Global Importers

• Market Access Protection: Non-compliant shipments risk being blocked at EU customs, causing costly delays, storage fees, and lost sales windows.
• Supply Chain Accountability: REACH shifts legal exposure onto anyone who places goods on the EU market — including importers with no direct chemical manufacturing — making supplier verification a business necessity, not a formality.
• Retailer & Marketplace Requirements: Major EU retailers and platforms increasingly require REACH/SVHC test reports as a precondition for listing approval, independent of government enforcement.

References

1. European Parliament and Council of the European Union. Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Official Journal of the European Union, L 396, 30 December 2006. Available via EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj/eng
2. European Chemicals Agency (ECHA). "REACH Legislation." https://www.echa.europa.eu/regulations/reach/legislation
3. European Chemicals Agency (ECHA). "Candidate List of Substances of Very High Concern for Authorisation." https://echa.europa.eu/candidate-list-table
4. European Chemicals Agency (ECHA). "Understanding REACH — Authorisation and Substances of Very High Concern." https://echa.europa.eu/understanding-reach
5. European Chemicals Agency (ECHA). "Regulation (EC) No 1907/2006, Article 33 — Duty to Communicate Information on Substances in Articles." Text via EUR-Lex: https://eur-lex.europa.eu/eli/reg/2006/1907/oj/eng
6. European Parliament and Council of the European Union. Directive 2011/65/EU on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS). Official Journal of the European Union, L 174, 1 July 2011.
7. European Commission — Environment. "REACH Regulation." https://environment.ec.europa.eu/topics/chemicals/reach-regulation_en
8. European Commission. "Safety Gate: EU Rapid Alert System for Dangerous Non-Food Products." https://ec.europa.eu/safety-gate/