REACH Compliance

Know what’s in your chemicals, and prove it before you place them on the EU market

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is an EU regulation (EC 1907/2006) governing the manufacture, import, and use of chemical substances — on their own, in mixtures, or contained in articles (products). It shifts the burden of proof onto businesses: “no data, no market” is the operating principle, meaning substances without adequate safety data cannot legally be placed on the EU market.

We help you determine your obligations, manage registration or notification, and maintain compliance as your product range and REACH’s substance lists evolve.

Which obligation applies to you?

 Applies to you if…
RegistrationYou manufacture or import a substance into the EU at ≥1 tonne/year
SVHC notification (Article 33)Your article contains a Substance of Very High Concern above 0.1% w/w — you must inform customers/consumers
AuthorisationYour substance is on the Authorisation List (Annex XIV) — use requires explicit EU approval
Restriction complianceYour substance/use is limited or banned under Annex XVII (e.g. certain phthalates, PAHs, heavy metals)
Only Representative (OR) routeYou’re a non-EU manufacturer exporting into the EU without an EU-based legal entity

Who it covers: manufacturers and importers of chemicals, formulators of mixtures (paints, coatings, cleaning products), and producers of articles — textiles, toys, electronics, furniture, jewellery — where a chemical substance is present.

Typical timeline: Registration can take 6 months to over a year depending on substance tonnage band and data availability; SVHC notification and restriction compliance checks typically take 3–6 weeks.

Process

Step 1 — Determine your role and obligation
We establish whether you’re a manufacturer, importer, downstream user, or only representative under REACH, and which specific obligation — registration, notification, authorisation, or restriction compliance — applies to your substances or articles.

Step 2 — Substance inventory and screening
Every substance in your product or supply chain is identified, including those present in raw materials, coatings, additives, and packaging, and checked against the Candidate List (SVHCs), Authorisation List (Annex XIV), and Restricted Substances List (Annex XVII).

Step 3 — Tonnage and pre-registration check (for registration route)
Annual EU import/manufacture volume is calculated to determine the applicable tonnage band, which sets the data requirements and registration deadline.

Step 4 — Data gathering and gap analysis
Existing toxicological, ecotoxicological, and physicochemical data is reviewed against REACH’s data requirements for the relevant tonnage band; gaps are identified for further testing or literature/read-across justification.

Step 5 — Joint submission and registration dossier (for registration route)
Substances are typically registered jointly with other manufacturers/importers of the same substance through a Joint Submission, sharing data costs. A technical dossier and, above 10 tonnes/year, a Chemical Safety Report (CSR) are compiled and submitted via IUCLID/REACH-IT.

Step 6 — SVHC and restriction compliance (for article producers)
Where a substance is present above threshold, we prepare Article 33 communication content for your customers and, where required, the SCIP database notification (linked to the EU Waste Framework Directive).

Step 7 — Only Representative appointment (for non-EU manufacturers)
Where you have no EU legal entity, we help appoint or act as your Only Representative to hold REACH obligations on your behalf for EU-bound shipments.

Step 8 — Ongoing monitoring
The Candidate List and restriction annexes are updated periodically (typically twice a year for SVHCs). We track updates against your product range so new obligations aren’t missed.

Documents & Information Required

About the substance/product

  • Full composition or formulation breakdown, including additives and impurities
  • Safety Data Sheets (SDS) for all raw materials and substances
  • CAS numbers for each substance where available
  • Bill of Materials for articles, identifying chemical content per component

About your role and volume

  • Import/manufacture volume records (annual tonnage into the EU)
  • Supply chain map — upstream suppliers and downstream customers/uses
  • Existing REACH registration numbers, if substances are already registered by suppliers

Supporting technical data

  • Existing toxicological/ecotoxicological study reports, if available
  • Physicochemical property data
  • Any prior CLP (classification and labelling) documentation
  • Read-across or QSAR justifications, where testing is being avoided under REACH’s data-sharing principles

For SVHC/article compliance

  • Test reports confirming SVHC concentration levels, where relevant
  • Customer/end-user list for Article 33 communication obligations
  • SCIP database submission details, where applicable

For non-EU manufacturers

  • Only Representative appointment letter/agreement
  • EU importer details, if using an EU-based importer instead

Notes

  • Substance data is often held by raw material suppliers rather than the product manufacturer — early supplier engagement significantly shortens this process.
  • The Candidate List (SVHCs) is updated periodically; a “clean” product today can require new action after the next update.

Benefits

Legal market access in the EU
Substances requiring registration cannot be legally manufactured or imported into the EU without one — non-compliance can mean products being withdrawn from sale or blocked at customs.

Avoids penalties and enforcement action
EU member states enforce REACH independently, with fines and in some cases criminal liability for serious or repeated non-compliance.

Unlocks EU supply chains
Downstream EU manufacturers and retailers will often refuse to purchase from suppliers who can’t demonstrate REACH status — compliance is frequently a condition of doing business, not just a legal formality.

Reduces product liability and recall risk
Understanding exactly what’s in your product, at what concentration, materially lowers the risk of a restricted-substance discovery leading to a recall or regulatory action later.

Builds trust with EU customers and partners
Being able to promptly provide SDS, Article 33 declarations, and SCIP data when asked is now a basic expectation in B2B chemical and article supply relationships in the EU.

Overlaps with other regulatory regimes
REACH compliance work shares significant ground with RoHS, CLP classification, and even US TSCA — the substance and supply chain data gathered here typically accelerates work on those regimes too.

Improved supply chain visibility
The substance-mapping process frequently surfaces undocumented or poorly traced materials in the supply chain — valuable to fix regardless of REACH, for quality and risk management generally.