REACH certificate explained for buyers and their suppliers
A REACH certificate is usually a supplier statement, not ECHA product approval. Learn what to request and what a useful declaration should cover.
A REACH certificate usually means a supplier's compliance statement or supporting test documentation, not official ECHA product approval. EU REACH does not establish a general product certificate or prescribed general declaration of conformity.
For procurement teams, the useful question is what the document actually covers. Ask which products, destination market and REACH duties the supplier assessed. A statement saying only "REACH certified" leaves those questions unanswered.
What does REACH certification mean?
Buyers may ask for a "REACH certificate of compliance", "REACH declaration" or "REACH statement". Treat those labels as a request for evidence. The title alone does not tell you whether the supplier assessed registration, substance communication or restrictions.
A registration number is different. Under Article 6, registration generally applies to substances manufactured or imported at one tonne or more per year, unless otherwise provided. This includes substances on their own or in mixtures. It does not mean every finished product needs its own registration number. Articles 5 and 6 set out these registration duties.
ECHA assigns a registration number once the registration is complete. But its completeness check does not assess the quality or adequacy of submitted data or justifications. A number therefore does not prove every REACH duty has been met. See Article 20 and ECHA's explanation of the completeness check.
A test report has limits too. Request the tested sample, substances covered and report reference. Use the report only for conclusions its scope supports, rather than treating it as universal approval.
Which evidence should you request?
Start by identifying whether the supply is a substance, mixture or article. The required information differs. A generic certificate cannot replace information that REACH requires for that supply.
Substances and mixtures
Request the safety data sheet when Article 31 requires one. Its conditions cover hazardous substances and mixtures, plus specified other cases. Certain non-hazardous mixtures require an SDS on request. An SDS is not universally required for every substance or mixture. Article 31 contains the conditions.
Where no SDS is required, check the applicable Article 32 information. This can include authorisation and restriction information, plus available information needed for appropriate risk management. Relevant registration numbers are required only within the provision's scope. Do not demand a registration number for every ingredient without checking the provision's scope. Article 32 qualifies those information duties.
Articles and complex products
For articles, ask which Candidate List version the supplier assessed. Under Article 33, suppliers must give recipients sufficient safe-use information when a Candidate List substance exceeds 0.1% weight by weight. That information must include at least the substance name. The threshold triggers communication, not an automatic product ban.
There is no one-tonne threshold for Article 33. Nor is the consumer response deadline a routine B2B grace period. Consumers must receive the corresponding information free within 45 days of a request. Supply-chain duties apply directly after Candidate List inclusion, as ECHA explains.
For complex products, don't simply average the substance concentration across the whole assembly. Assess the threshold against each relevant constituent article that retains its article status. The Court of Justice confirmed this in Case C-106/14.
Restrictions need a separate check
A negative SVHC statement does not settle restriction compliance. Article 67 requires compliance with applicable Annex XVII restriction conditions for substances on their own, in mixtures or in articles. Check each relevant entry's scope, exceptions and application dates. Registration does not replace this duty.
A practical REACH declaration outline
Use the following as a suggested procurement format, not an official or legally prescribed REACH template. These fields help define the supplier's statement. They do not create a compliance finding.
- Identify the supplier's legal entity, contact and responsible signatory. Add the issue date and document revision.
- List the exact products, part numbers and revisions covered. State the destination market and supply-chain role.
- Describe the evidence basis: composition data, supplier information and any relevant testing. Give document references and explain coverage limits.
- For articles, identify the Candidate List assessment date or version. Record substances above 0.1% weight by weight, affected constituent articles and required safe-use information.
- If no substances exceed that threshold, define the products, evidence and list version supporting the conclusion. Avoid an undefined "SVHC-free" claim.
- Identify applicable Annex XVII entries and the evidence supporting compliance with their conditions.
- For substances and mixtures, reference the required SDS or applicable Article 32 information. Include relevant registration or authorisation information as applicable.
- Give a contact and update process for changes in composition, regulatory scope or supporting evidence.
Don't start with a pre-filled "fully REACH compliant" signature block. Ask the supplier to explain the assessment behind its conclusion. A signed page without defined coverage still leaves you chasing the evidence.
Check the market and date before accepting it
An EU REACH declaration should not automatically be accepted as UK REACH evidence. UK REACH applies in Great Britain: England, Scotland and Wales. EU REACH continues to apply in Northern Ireland, and the two systems operate independently. HSE explains the territorial distinction.
For US suppliers, specify the destination market rather than asking for an undefined worldwide certificate. Match the declaration to the products being supplied and the evidence supporting it. Request reassessment when composition, relevant rules or evidence changes, rather than treating the statement as permanently valid.
For the legal background, read RegAffairs AI's answer on REACH certificates and supplier declarations. It explains the underlying legal duties.