REACH Compliance: What the Regulation Requires
A customer sends a form with one line on it. Confirm your products are REACH compliant.
There is no box to tick. REACH hands out no pass mark. Nobody sends you a certificate when you are done. What the law asks of you depends on what you make, what you buy, and where you sit in the chain.
At a glance:
- REACH is Regulation (EC) No 1907/2006, in force since 1 June 2007.
- It puts the burden of proof on companies, not on authorities.
- Your duties follow your role, not your industry.
- Registration starts above one tonne a year, per company, per substance.
- For finished goods, the Candidate List is the trap. Above 0.1% by weight you owe your buyer information, per ECHA on communication in the supply chain. At 0.1% plus one tonne, you also owe ECHA a notification.
- Firms outside the EU cannot register. An EU importer or an only representative carries it.
What REACH compliance actually means
REACH compliance is the ongoing duty to know which controlled substances sit in what you sell, and to act on each rule that attaches to them. It is a state you hold. It is not a document you buy once.
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. ECHA is blunt about where the work sits. The rules place "the burden of proof on companies", which must find and manage the risks of what they sell in the EU. Nobody screens your goods for you.
The reach is wider than most firms expect. ECHA lists clothes, furniture and electrical goods as products in scope. Import a kettle and you are in scope. For the background, see what REACH is.
Your duties follow your role
The first question is not what you sell. It is what you are, in the law's terms.
| Your role | What REACH asks of you |
|---|---|
| Maker in the EU | Register what you make above one tonne a year. Assess the hazards. Pass safety data down the chain. |
| Importer into the EU | The same duty for substances and mixtures. Plus the article duties below, for finished goods. |
| Downstream user | Work within the conditions in the safety data sheet. Tell your supplier if your use is not covered. |
| Distributor | Pass data up and down the chain, including safety data sheets and Candidate List facts. |
| Firm outside the EU | Not bound. The duty falls on your EU importer, or on an only representative you name in the EU. |
That last row trips up non-EU suppliers. ECHA puts it plainly. A firm based outside the EU is not bound by REACH, even when it ships into the EU. The duty to register sits with the EU importer. It can also sit with an only representative, named by the non-EU maker and based in the EU.
Naming one moves the duty. Skipping it leaves your buyer holding it. That is why the form landed on your desk.
Registration and the one tonne line
Registration is the duty to gather data on a substance you make or import above one tonne a year, weigh up its risks, and file that with ECHA.
Three points matter in practice. The line is drawn per company, per substance, per year, so volumes do not merge across group firms. The rule runs on "one substance, one registration", so firms filing on the same substance file together. A fee is usually charged.
Registration covers substances on their own, substances in mixtures, and some cases of substances in articles. That last case is narrow. It is not the duty most importers of finished goods will meet. The next one is.
If you import finished goods, this part catches you
An article is an object given a shape, surface or design during making, where that shape decides its job more than its chemistry does. ECHA offers clothing, flooring, furniture, jewellery, newspapers and plastic packaging as examples.
An SVHC is a Substance of Very High Concern, one that meets any of three tests. The first is carcinogenic, mutagenic or toxic for reproduction, in category 1A or 1B under CLP. The second is persistent, bioaccumulative and toxic, or very persistent and very bioaccumulative, under REACH Annex XIII. The third is a case-by-case finding of equal concern. Once named, it joins the Candidate List. For more, see what an SVHC is.
Joining that list starts two separate duties. They have different triggers.
| Duty | Trigger | What you must do | Basis |
|---|---|---|---|
| Communication | Above 0.1% by weight in the article | Give recipients enough to use it safely, at minimum the substance name. Recipients are trade users and distributors, not consumers. | Article 33(1) |
| Consumer request | A consumer asks | Answer within 45 days, free of charge. | Article 33(2) |
| Notification | Both 0.1% by weight and over one tonne a year | Tell ECHA, within six months of the listing. | Article 7(2) |
Two exemptions cut the notification duty. The first applies where you can rule out exposure to people and the environment in normal use and disposal, including where you give the buyer proper instructions. The second applies where the substance is already registered in the EU for that use.
Note what the communication duty leaves out. There is no tonnage floor on it. Take a single imported chair, for example, with a plasticiser above 0.1% in one armrest. That one item carries the duty, and the 45 day clock runs whether or not your answer is ready.
Restriction and authorisation
Two more tools sit above the Candidate List.
Restrictions are hard limits on making, selling or using a substance. They live in Annex XVII. Most enforcement against imported consumer goods happens here, because the limits are specific and can be tested. See REACH Annex XVII for how an entry reads. Or check ECHA's Restriction List itself.
Authorisation goes further. An SVHC can move from the Candidate List to the Authorisation List. After that, nobody may use it for a listed use without specific consent. The aim is that these substances give way to safer ones, where workable alternatives exist.
There is no REACH certificate
Search for a "REACH compliance certificate" and sellers will offer you one. No such thing exists in the law.
What does exist is evidence. A registration number. A safety data sheet. A supplier declaration that names the substances checked and the entries tested. The lab reports behind it.
A lab report is a real document, but read what it covers. It certifies a result, against named entries, on one sample. Say a report clears a jacket for azo dyes under entry 43. That is useful, and it says nothing about the nickel in the zip. Treating a narrow report as whole-product proof is how buyers end up with the wrong test on file.
So when a customer asks you to confirm REACH compliance, the useful answer is specific. Name what you checked, against which list, on what date.
Where Bindu fits. Bindu tracks which of your products hold which controlled substances, keeps each duty attached to the product it belongs to, and files the evidence against it. The answer exists before the form arrives. See how it works.
FAQ
What is REACH compliance? It is the ongoing duty under Regulation (EC) No 1907/2006 to know which controlled substances sit in what you make or sell. You must then meet each rule attached to them. That covers registration above one tonne a year, Candidate List duties, Annex XVII limits, and authorisation where it applies. The burden of proof sits with the company.
Source: ECHA: Understanding REACH
Do I have to register if I only import finished products? Usually not. Registration covers substances on their own, in mixtures, and some cases of substances in articles. Importers of finished goods more often meet the article duties instead. Those are communication above 0.1% by weight, and notification where the substance is both above 0.1% and over one tonne a year.
Source: ECHA: Registration
Is there a REACH compliance certificate? No. REACH makes no provision for a certificate of compliance. What you can hold is a registration number, a safety data sheet, a supplier declaration and lab reports against named entries. A test report shows one result on one sample. It is not proof of compliance with the whole regulation.
Source: EUR-Lex: Regulation (EC) No 1907/2006
What is the 0.1% rule in REACH? Where a Candidate List substance sits above 0.1% by weight in an article, the supplier must give recipients enough to use it safely. At minimum that means the substance name. Consumers who ask must be answered within 45 days, free of charge. Notification to ECHA is separate, and needs both 0.1% and more than one tonne a year.
Source: ECHA: Communication in the supply chain
Source: ECHA: Notification of substances in articles
Are REACH and RoHS the same thing? No. They are separate laws with separate scopes. REACH covers chemicals broadly, across almost every sector and product type. RoHS limits a defined set of hazardous substances in electrical and electronic goods, such as lead and mercury. A product can pass one and fail the other. A supplier declaration should say which law it answers.
Source: ECHA: Understanding REACH
What if my non-EU supplier ignores REACH? Nothing happens to them directly. REACH does not bind firms based outside the EU. The duty falls on the EU importer, or on an only representative named in the EU. That is why EU buyers push the form upstream. Without the supplier's data, the importer cannot discharge a duty that is legally theirs.
Source: ECHA: Understanding REACH