Q.01

What does REACH compliant mean for products?

"REACH compliant" isn't a term REACH defines. Article 3 of Regulation (EC) No 1907/2006 has no such definition, and the Regulation provides no certificate or mark [1]. In practice, a supplier who calls a product "REACH compliant" is claiming that it meets the duties the Regulation places on that product. Those duties depend on whether the product is a substance, a mixture or an article. For most finished goods (articles), the claim usually rests on three checks: no Annex XVII restriction is breached; Candidate List SVHCs above 0.1% w/w are communicated (and notified to ECHA where required); and registration is in place wherever it applies.

Approach: I read the current consolidated text of REACH as published in the Official Journal: the definitions, registration, information-duty, authorisation and restriction articles.

First, what kind of product is it?

  • Substance: "a chemical element and its compounds…" [1]
  • Mixture: "a mixture or solution composed of two or more substances" [1]
  • Article: "an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition" [1]

What a compliance claim has to cover

ObligationWho it applies toWhat REACH requires
Registration, "no data, no market" (Art. 5, 6)Manufacturers and importers of substances, on their own or in mixturesSubstances "shall not be manufactured in the Community or placed on the market unless they have been registered" where required [2]. The trigger is 1 tonne or more per year [3].
Registration of substances in articles (Art. 7(1))Producers and importers of articlesRequired only when both conditions are met: more than 1 t/y of the substance across the articles, and the substance is intended to be released under normal or reasonably foreseeable conditions of use [4].
SVHC notification to ECHA (Art. 7(2))Producers and importers of articlesRequired for a Candidate List substance present at more than 1 t/y and above 0.1% w/w. It does not apply if exposure can be excluded, including at disposal; in that case the producer or importer must supply instructions to the recipient. It applies six months after the substance is added to the Candidate List [4].
SVHC information in the supply chain (Art. 33)Every supplier of an article, including distributorsAbove 0.1% w/w of a Candidate List substance, the supplier "shall provide" recipients with enough information for safe use, as a minimum the substance name. Consumers must get the same on request, free of charge, within 45 days. This has no tonnage threshold [5].
Restrictions, Annex XVII (Art. 67)Substances on their own, in mixtures or in articlesThey "shall not be manufactured, placed on the market or used unless it complies with the conditions of that restriction" [6].
Authorisation, Annex XIV (Art. 56)Manufacturers, importers and downstream users of substancesAn Annex XIV substance cannot be placed on the market for a use, or used, unless the use is authorised or exempted, the sunset date has not passed, or an application is pending [7]. This governs use inside the EU. It does not by itself ban imported articles containing the substance; those are dealt with through Annex XVII.
Safety data sheets (Art. 31)Suppliers of substances and mixturesAn SDS is required for hazardous substances and mixtures, PBT/vPvB substances and Candidate List substances [8]. It must be updated "without delay" after new hazard information or an authorisation or restriction decision [9].

Points that change the answer

  • The Candidate List keeps growing. SVHCs are substances meeting the Article 57 criteria: CMR Cat. 1A/1B, PBT, vPvB, or equivalent concern such as endocrine disruptors [10]. ECHA "shall publish and update" the list [11]. A compliance statement is only as current as the Candidate List version it was checked against, so it should carry a date and list version.
  • Non-EU manufacturers may appoint an EU-established Only Representative to carry out importers' registration obligations. Importers in that supply chain are then treated as downstream users [12].
  • Scope exclusions: REACH does not apply to substances under customs supervision in transit or temporary storage, to non-isolated intermediates, or to the transport of dangerous goods. Waste is not a substance, mixture or article under REACH [13]. Polymers are exempt from registration, though their monomers can still need registering under Art. 6(3) [14][3].
  • Sector carve-outs: for medicines and for food and feed uses, the registration, downstream-user, evaluation and authorisation titles do not apply to the extent the substance is used in those products [13]. Cosmetics are carved out of Annex XVII restrictions that address human-health risks [6].

If you tell me the product type and materials, or share a supplier's declaration, I can check it against the current Candidate List and the relevant Annex XVII entries.

Q.02

What should I check in a supplier's REACH declaration?

A supplier's REACH declaration is only useful if it says what product it covers, which version of the Candidate List and Annex XVII it was checked against, and what the supplier actually found. A bare "REACH compliant" claim does neither. Check each point below against the duty that applies to your product (substance, mixture or article). Each duty comes from the current consolidated REACH text (02006R1907-20260622).

Approach: I read the in-force REACH articles on articles, safety data sheets, authorisation and restrictions, the ECHA Candidate List and Annex XVII entries, and Article 9 of the Waste Framework Directive.

1. Scope and identity

  • What it covers: specific part numbers or product codes and the supplier's legal entity, plus a date and a named signatory. A blanket statement covering "all our products" can't be traced to what you buy.
  • Who the supplier is in REACH terms: "importer" and "distributor" are defined as persons "established within the Community" [1]. A non-EU supplier can't take on the EU importer's duties itself. Find out who holds them: you, or an Only Representative named in the declaration.

2. Candidate List (SVHC) statement

  • List version: the declaration should name the Candidate List date it was checked against. ECHA "shall publish and update" the list "without delay" after each inclusion decision [11]. The latest additions in the ECHA data are dated 4 February 2026. They include n-hexane (Article 57(f), human health) [15] and Bisphenol AF and its salts (toxic for reproduction) [16]. Before that came 1,1'-(ethane-1,2-diyl)bis[pentabromobenzene] on 5 November 2025 [17]. Treat a declaration that predates February 2026 as out of date.
  • Threshold and content: the duty applies "above 0,1 % weight by weight (w/w)". The supplier "shall provide" enough information for safe use, "as a minimum, the name of that substance" [5]. If an SVHC is present, the declaration should name it and give its concentration range and safe-use information. "Contains SVHC" with no name doesn't meet that minimum.
  • Pass-on to consumers: you will need this information to answer a consumer request within 45 days, free of charge [5].
  • SCIP: Member States must ensure that every supplier of an article provides its Article 33(1) information to ECHA "as from 5 January 2021". ECHA keeps a database of these submissions [18]. If an SVHC is declared, ask for the SCIP notification number, or plan to make the submission yourself.

3. Annex XVII restrictions

  • Restricted substances "shall not be manufactured, placed on the market or used" unless they meet the conditions of the restriction. This covers substances in articles [6].
  • Ask which entries were assessed and on what evidence, such as test reports with method, lab and date, or a materials declaration. "Complies with Annex XVII" alone doesn't show this.
  • Check that recent entries are covered. The newest entries in the ECHA list run to entry 83: 79 undecafluorohexanoic acid and its ammonium salt [19], 80 DMAC [20], 81 NEP [21], 82 PFAS [22] and 83 2,4-dinitrotoluene [23]. Older declarations often stop much earlier.

4. Registration

  • Substances and mixtures: ask for registration numbers, or the reason none is needed (for example, below 1 t/y, polymer or exempt use). Safety data sheet updates after registration "shall include the registration number" [9].
  • Articles: the declaration should say whether any substance is intended to be released. Registration is triggered only when release is intended and more than 1 tonne per producer or importer per year is present [4].
  • ECHA notification (Article 7(2)): if you are the EU producer or importer, you need the SVHC tonnage to judge this duty. It applies at more than 1 t/y and above 0.1% w/w, six months after the substance is listed. It falls away if exposure can be excluded, including at disposal, in which case "appropriate instructions" must be supplied to the recipient [4].

5. Authorisation (substances and mixtures)

  • If an Annex XIV substance is supplied for an authorised use, holders and downstream users "shall include the authorisation number on the label" [24]. Check that the number is on the label and that your use falls within the authorisation.

6. Safety data sheet (substances and mixtures)

  • An SDS is required for hazardous substances and mixtures, PBT/vPvB substances and Candidate List substances [8]. It must be dated, have the 16 set headings and be in an official language of the Member State where it is placed on the market [8].
  • It must be updated "without delay" when new hazard information arrives, when an authorisation is granted or refused, or when a restriction is imposed. The revised version must go to all recipients of the previous 12 months [9]. Compare the revision date with the recent Candidate List and Annex XVII changes above.

Red flags

  • No date, no list version, or no product scope.
  • "REACH compliant" or "free of SVHC" with nothing to back it up.
  • An SVHC declared without its name or safe-use information.
  • A non-EU company calling itself the "importer".
  • A commitment to update the declaration only on request. The Article 33 duty is triggered by each new Candidate List entry, so the declaration should be updated whenever the list changes.

If you share the declaration, I can check its substances against the current Candidate List, Annex XIV and Annex XVII entries.

Q.03

How does this differ for the UK?

For Great Britain (England, Scotland and Wales), you check the declaration against UK REACH, which HSE runs, not against EU REACH. The articles duties (0.1% w/w communication, 45-day consumer response, Article 7 registration and notification) are worded the same. What differs is the lists, the parties and the deadlines. An EU declaration doesn't show GB compliance unless it names the GB Candidate List and GB Annex XVII versions and a GB-established duty-holder.

Approach: I read the GB assimilated text of UK REACH from legislation.gov.uk, HSE's GB Candidate List, Authorisation List and Restrictions list, and Defra's published approach to the UK REACH Candidate List.

What stays the same

  • Article 33: the GB text is the same. Above 0.1% w/w of a Candidate List substance, the supplier "shall provide" enough information for safe use, as a minimum the substance name. Consumers must get it free of charge within 45 days [25].
  • Article 7: registration is needed for substances intended to be released at over 1 t/y. Notification is needed at over 1 t/y and above 0.1% w/w, six months after listing, with the same exposure-exclusion exemption. The difference is that both go to "the Agency" [26]. In UK REACH that means HSE [27].
  • Article 67 (restrictions) and Article 65 (authorisation number on the label) use the same wording [28][29].

What to check differently

CheckUK REACH (GB) positionWhat it means for the declaration
Which Candidate ListHSE keeps its own list. Every substance on ECHA's list just before IP completion day was carried over (Art. 59(1A)) [30]. Additions since then follow a separate GB process.The declaration must cite the GB list version. The two lists are not identical.
List currencyThe latest GB additions are dated 19 October 2026: 23 entries, e.g. perfluoroheptanoic acid and its salts, MCCP, UV-326 [31][32][33]. The batch before that is dated 15 June 2026: 31 entries, e.g. dioctyltin dilaurate, TBNPA, N-(hydroxymethyl)acrylamide [34][35][36].Treat a GB declaration dated before 19 October 2026 as out of date. The GB list also shows Bisphenol AF (by its chemical name) and its salts as added on 19 October 2026 [37]. I found no n-hexane entry on the GB list, though it is on the EU list.
Where GB policy is headingDefra says that from 24 February 2026 the 2021 interim principles "no longer apply". Substances added to the EU list since 1 January 2021, and later EU additions, "will be reviewed and added to the UK REACH candidate list where appropriate" [38][39].Expect GB additions to keep following EU entries. Each GB inclusion date restarts the duties for that substance.
Annex XVII restrictionsHSE's GB restrictions list runs to entry 74, diisocyanates [40].The EU entries 79 to 83 I listed last time (PFHxA, DMAC, NEP, PFAS, 2,4-dinitrotoluene) have no counterpart in the GB list. A declaration can be compliant in GB and not in the EU, so it should state which regime's entries were assessed.
Who is the importer"Importer" means a person "established within Great Britain", and "import" means "the physical introduction into Great Britain" [41]. A non-GB manufacturer may appoint a GB-established Only Representative. The importers in that supply chain are then treated as downstream users (Art. 8) [42].An EU company, or an EU Only Representative, is outside GB here. Ask for the GB Only Representative's name, or accept that you are the GB importer.
Registration statusEU registrations held by GB-established registrants became GB registrations ("grandfathering") [43]. GB downstream users and distributors who imported from EU registrants could continue under Art. 127E, provided they supplied the required information within the 300-day period (the "DUIN" route) [44]. Full data submission deadlines are tiered by hazard and tonnage, see below [45].Ask for the GB registration number or the DUIN basis. An ECHA registration number alone does not cover GB supply.
AuthorisationGB has its own Annex XIV list and its own authorisation decisions. An EU authorisation whose holder was not established in GB "ceases to have effect" (Art. 127F) [46].For Annex XIV substances, the authorisation number on the label must be a GB authorisation number.
Safety data sheetsThe safety data sheet "shall be supplied in English and may also be supplied in any other language" [47].Check the SDS is in English, cites UK REACH and the GB mandatory classification and labelling list, and has been updated for the GB list changes.
SCIPThe GB Article 33 has only the recipient and consumer duties [25]. I found no GB equivalent of the EU SCIP database submission in the sources I searched.Don't treat a SCIP number as evidence of GB compliance.

GB registration deadlines (Art. 127P, "relevant post-IP completion period")

  • 27 October 2029: substances on the Candidate List carried over from the EU, or added on or before 27 October 2027. Also CMR Cat. 1A/1B substances at 1 t/y or more, Aquatic Acute 1 or Aquatic Chronic 1 substances at 100 t/y or more, and any substance at 1,000 t/y or more.
  • 27 October 2030: substances added to the Candidate List between 28 October 2027 and 27 October 2028, and any substance at 100 t/y or more.
  • 27 October 2031: any substance at 1 t/y or more.

[45]

Northern Ireland

UK REACH is written for Great Britain. Goods coming into GB from Northern Ireland get special treatment as a "protected NI import" (Art. 139A) if all three apply:

  • the substance, mixture or article was made in Northern Ireland;
  • it is supplied from Northern Ireland and is a qualifying Northern Ireland good;
  • the supplier is an EU REACH registrant or downstream user.

The GB importer is then treated as a downstream user. Before importing at 1 t/y or more, it must notify HSE and supply the information listed in that article [48]. For NI-sourced goods, check that the declaration shows each of those three points.

Extra red flags for a GB declaration

  • It cites only the ECHA Candidate List, or only EU Annex XVII.
  • It gives an ECHA registration number with no GB registration or DUIN basis.
  • It names an EU or EU Only Representative as the "importer" for GB supply.
  • It is dated before the GB list update of 19 October 2026.

If you share a declaration, I can check its substances against both the GB and EU Candidate Lists and restriction lists side by side.

Q.04