REACH compliance for checking products and supplier declarations
REACH compliance depends on your product, role and market. Check supplier declarations against registration, restrictions and chemical information duties.
REACH compliance for products and supplier declarations
REACH compliance means meeting the chemical obligations that apply to your product, supply-chain role, use and destination market. A supplier's "REACH compliant" declaration supports that assessment, but does not establish compliance with every applicable duty under the REACH regulation.
For UK buyers, the destination matters from the start. EU REACH and UK REACH operate independently. EU REACH continues to apply in Northern Ireland, while UK REACH covers Great Britain: England, Scotland and Wales. HSE states that the two regimes operate independently. A declaration for one regime doesn't automatically cover the other.
What does "REACH compliant" mean?
The phrase needs a scope. Which product does it cover, where will it be supplied, and which obligations were assessed? Registration, restrictions, authorisation and supply-chain information have separate conditions. A registration number or Candidate List statement answers only part of that assessment. See Articles 5 to 8, 31 to 33, 56 and 67.
Start by deciding whether you supply a substance, mixture or article. Under Article 3, an article's shape, surface or design determines its function more than its chemical composition. A chemical blend and a finished component therefore need different checks. Your role also matters: the regulation distinguishes importers, downstream users and distributors. These definitions appear in Article 3.
An exemption needs the same care. An exemption from registration does not establish exemption from restrictions or information duties. Check the conditions of the relevant Article 2 exclusion or exemption rather than treating it as approval for the whole product.
What a REACH certificate or declaration can establish
A document headed "REACH certificate" does not by itself establish that all applicable REACH obligations have been met. Assess its contents against the separate registration, information, authorisation and restriction duties. The heading is no substitute for evidence about the supplied product.
Ask for a dated declaration that identifies the covered products and the assessment's scope. Does it address only Candidate List substances or also relevant restrictions? Which list version was used? These are procurement checks derived from the applicable legal duties, not mandatory fields in a universal REACH form.
A vague declaration leaves the buyer with another round of questions (usually another email). "No SVHC above 0.1%" does not answer whether a product meets an applicable Annex XVII restriction. Equally, a registration number does not answer whether a covered use requires authorisation. Those checks follow different REACH provisions.
For qualifying substances and mixtures, Article 31 sets safety data sheet duties. Article 32 covers information where an SDS is not required. An SDS is not a universal finished-article certificate. Ask for the information appropriate to what you buy, rather than an SDS for every component. See Articles 31 and 32.
Check the EU REACH duties that apply to your product
Registration coverage
Registration generally applies at one tonne or more of a substance per manufacturer or importer per year, subject to exemptions. The threshold is the quantity of the substance, including when that substance is in a mixture, not the total weight of the finished mixture. It does not create a general exemption from restrictions below one tonne. See Articles 5 and 6.
Finished articles have different registration conditions. Article 7(1) concerns a substance intended to be released under normal or reasonably foreseeable use, and only where its quantity in those articles is over one tonne per producer or importer per year. Article 7(6) exempts a substance already registered for that use. Do not demand a registration number for every finished part. Article 6 counts one tonne or more, while Article 7 counts only over one tonne. See Article 7.
Candidate List substances in articles
Under Article 33, an article containing a Candidate List substance above 0.1% weight by weight triggers information duties. The supplier must give recipients sufficient available information for safe use, including at least the substance name. Article 33 has no annual-tonnage threshold. Consumers can request the relevant information free of charge, with a 45-day response deadline. That deadline is not a grace period for business-recipient information. See Article 33.
For assembled products, assess constituent articles that retain article status. Do not dilute their concentration across the weight of the whole assembly. The Court confirmed this approach in case C-106/14, paragraph 82.
Notification to ECHA under Article 7(2) is separate from supplier communication. It requires Candidate List status, concentration above 0.1% weight by weight, and a quantity of that substance in the relevant articles over one tonne per producer or importer per year. Exceptions can apply, including prior registration for that use and the Article 7(3) exclusion of exposure, including disposal. A notification exception does not remove Article 33 communication duties. See Article 7.
Candidate List inclusion is not itself a blanket ban on an article. "REACH compliant" need not mean "SVHC-free". Assess information duties alongside any applicable restriction or authorisation conditions under REACH.
Restrictions and authorisation
Annex XVII restrictions can cover substances on their own, in mixtures or in articles within the relevant entry's scope. Each entry has its own limits, uses, exceptions and application dates. But the Article 33 threshold of 0.1% weight by weight is not a universal restriction limit. Read the applicable entry under Article 67 and Annex XVII.
Authorisation under Article 56 and Annex XIV is separate and use-specific. A registration number does not replace an authorisation assessment. Check the covered substance and use against the authorisation provisions.
How to check a supplier's REACH declaration
To comply with REACH, match the evidence request to the product and the duty that actually applies. Use the questions below as a procurement workflow, not as a prescribed legal form.
| Check | What to ask the supplier |
|---|---|
| Product scope | Which part numbers, revisions and materials does the statement cover? |
| Market and role | Does it cover EU REACH, UK REACH for Great Britain, Northern Ireland, or more than one market, and which entity is responsible? |
| Assessment basis | When was the assessment made, and which Candidate List version and relevant restriction entries were assessed? |
| Article information | Does a constituent article contain a Candidate List substance above 0.1% weight by weight, and what safe-use information is needed? |
| Other applicable duties | What supports registration coverage, authorisation conditions or restriction compliance where relevant? |
The legal basis for these checks is in Articles 3, 5 to 8, 31 to 33, 56 and 67. For the market distinction, use HSE's EU and UK REACH overview.
Request material declarations or targeted test evidence where they help assess a relevant restriction. Do not turn that request into a blanket demand for third-party testing against every entry. Evidence should address the conditions of the applicable restriction.
Keep the evidence with the product record. Revisit it when materials, suppliers, uses, markets or relevant legal lists change. A declaration's age is a reason to review its basis. It is not proof that every later legal change affects that product. Review the evidence against relevant changes rather than using a fixed renewal interval.
UK and US supplier checks
For GB supply, check the GB regime rather than assuming an EU assessment transfers. HSE identifies registration responsibilities for in-scope GB manufacture or import at one tonne or more per substance annually, subject to exemptions and appropriate coverage. Use HSE's roles guidance. Its UK REACH Candidate List page is the official GB list-checking destination.
US exporters should identify who handles the import obligations in the destination market. EU REACH allows an eligible overseas manufacturer, mixture formulator or article producer to appoint an established Only Representative. Importers covered by that arrangement are treated as downstream users. Confirm that the actual supply is covered. Do not assume every overseas reseller can appoint one under Article 8.
For US-to-GB supply, identify the GB importer or the eligible supplier's GB-established Only Representative. An EU registration alone does not establish GB registration coverage. See GB Article 8 and HSE's roles guidance. This does not mean every product requires two registrations.
RegAffairs AI's answer on REACH compliance and supplier declarations cites the duties behind these checks.
Keep Northern Ireland separate from GB in the assessment. EU REACH continues to apply there. Do not describe a GB declaration as covering Northern Ireland without checking its stated scope.