What Is REACH Regulation
What is the REACH regulation?
REACH is the EU's main chemicals law: Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals. It covers making, placing on the market and using substances, whether on their own, in mixtures or in articles. It also set up the European Chemicals Agency (ECHA) [1][2]. The quotes below are from the current consolidated version (CELEX 02006R1907-20260622).
Purpose and principles (Article 1)
- Aim: "a high level of protection of human health and the environment, including the promotion of alternative methods for assessment of hazards of substances, as well as the free circulation of substances on the internal market while enhancing competitiveness and innovation" [1].
- Industry carries the burden: manufacturers, importers and downstream users must make sure the substances they handle "do not adversely affect human health or the environment."
- Precaution: the provisions are "underpinned by the precautionary principle" [1].
The main parts
| Part | What the text requires |
|---|---|
| Registration | "No data, no market" (Article 5): substances may not be made in the EU or placed on the market unless they are registered where registration is required [3]. Under Article 6, any manufacturer or importer of a substance at 1 tonne or more per year must register it with ECHA and pay a fee. Polymer makers must register monomers that make up 2% w/w or more of the polymer, where those monomers total 1 tonne or more per year [4]. |
| Evaluation | Covered by a separate Title of the Regulation. I did not pull that text here. |
| Authorisation | Applies to substances of very high concern (SVHCs). The aim is to make sure their risks "are properly controlled" and that they are "progressively replaced by suitable alternative substances or technologies where these are economically and technically viable." Applicants must analyse alternatives and whether substitution is feasible (Article 55) [5]. In practice: SVHCs are identified on the Candidate List and then included in Annex XIV. |
| Restriction | A substance with an Annex XVII restriction may not be made, placed on the market or used unless it meets the conditions of that restriction. Scientific research and development is exempt (Article 67) [6]. |
| ECHA | Article 75 set up the European Chemicals Agency to manage, and in some cases carry out, the technical, scientific and administrative work under REACH, and to keep it consistent across the EU [2]. |
Approach: All of this comes from the current consolidated text of Regulation (EC) No 1907/2006 as published in the Official Journal. I didn't go into the Article 2 exemptions, the evaluation provisions or the Annexes. I can look up any of these, or a particular substance's REACH status, if that's useful.
Who has to register under it?
Under REACH, registration falls on EU-established manufacturers and importers of a substance at 1 tonne or more per year, whether the substance is on its own or in a mixture (Article 6(1)) [4]. Some producers and importers of articles also have to register, and a non-EU manufacturer can pass the importer's obligations to an EU-based only representative. Distributors, consumers and downstream users don't register.
Who must register
| Who | When registration applies | Provision |
|---|---|---|
| Manufacturer (an EU-established person making the substance in the EU) | 1 t/y or more, on its own or in mixtures | Art 3(9), Art 6(1) [7][4] |
| Importer (an EU-established person "responsible for import"; import means physically bringing goods into the EU customs territory) | Same 1 t/y threshold | Art 3(10)-(11), Art 6(1) [7] |
| Manufacturer or importer of a polymer | Polymers themselves are not registered (Art 2(9)) [8]. They register the monomers and other substances not already registered further up the supply chain if both: (a) these make up 2% w/w or more of the polymer, and (b) their total is 1 t/y or more | Art 6(3) [4] |
| Producer or importer of articles | A substance in the articles must be registered if both: it totals over 1 t/y per producer or importer, and it is intended to be released under normal or reasonably foreseeable use. ECHA can also require registration if it suspects an unintended release poses a risk (Art 7(5)). Neither applies where the substance is already registered for that use (Art 7(6)) | Art 7(1), (5), (6) [9] |
| Manufacturer of an on-site isolated intermediate | 1 t/y or more. Reduced data requirements apply under strictly controlled conditions | Art 17 [10] |
| Manufacturer or importer of a transported isolated intermediate | 1 t/y or more. Above 1,000 t/y, Annex VII information is also needed | Art 18 [11] |
| Only representative of a non-EU manufacturer, formulator or article producer | Appointed by mutual agreement to carry out the importer's obligations. EU importers in that supply chain are then treated as downstream users | Art 8 [12] |
The Regulation calls the person who submits a registration the "registrant". That can be a manufacturer, an importer, or a producer or importer of an article (Art 3(7)) [7]. Every registration needs a fee under Title IX (Art 6(4)) [4].
Who does not register
- Distributors, retailers and consumers. A distributor only stores substances and places them on the market. "A distributor or a consumer is not a downstream user" (Art 3(13)-(14)) [7].
- Non-EU companies directly. The definitions of manufacturer and importer require establishment in the EU, so a non-EU company can only act through an importer or an only representative [7][12].
Exemptions and substances treated as already registered
- Outside REACH altogether (Art 2(1)-(2)) [13]:
- radioactive substances;
- substances under customs supervision in transit or temporary storage;
- non-isolated intermediates;
- waste.
- Uses exempt from registration (Art 2(5)) [13]: a substance used in human or veterinary medicinal products, or in food or feed (including food additives, flavourings and feed additives).
- Substances exempt from registration (Art 2(7)) [8]:
- substances listed in Annex IV or covered by Annex V;
- registered substances that are re-imported within the same supply chain;
- registered substances recovered in the EU, where the recovered substance is the same and the safety data sheet information is available.
- R&D:
- Product and process orientated R&D (PPORD) is exempt for five years once notified to ECHA. ECHA can extend this by up to 5 more years, or up to 10 for medicinal-product development or substances not placed on the market (Art 9) [14].
- Scientific research and development by definition covers volumes under 1 t/y (Art 3(23)) [15].
- Treated as already registered:
- plant protection and biocidal active substances (and plant protection co-formulants) approved under the listed EU legislation, for that use only (Art 15) [16];
- substances notified under Directive 67/548/EEC. Their notifiers must update the dossier when they reach the next tonnage band (Art 24) [17].
Related article obligation (a notification, not a registration): producers and importers of articles must notify ECHA of a Candidate List SVHC present above 0.1% w/w and over 1 t/y in total. This doesn't apply if they can rule out exposure to people and the environment, including at disposal (Art 7(2)-(3)) [9].
Approach: I worked from the current consolidated text of Regulation (EC) No 1907/2006 (CELEX 02006R1907-20260622): the definitions in Article 3, the scope and exemptions in Article 2, and the registration provisions in Articles 6-9, 15, 17-18 and 24. I didn't cover the information requirements for each tonnage band (Articles 10-12, Annexes VII-X) or the content of Annexes IV and V. I can pull either if you need them.
What's changing with the REACH revision?
The REACH revision isn't going ahead for now. On 27 April 2026, Environment Commissioner Jessica Roswall told the Parliament's ENVI Committee: "We have come to the conclusion to not open REACH at this point." The Parliament's Legislative Train marks the file "Blocked", with the Commission as the blocking institution (page last updated 20 September 2026) (EP Legislative Train). The Commission's own competitiveness tracker still lists "Targeted revision of the REACH Regulation" as "Planned, 2026" (Commission tracker). That tracker is out of step with the Commissioner's statement, and I found no adopted proposal.
How it got here
- 2023: RIVM's Bureau REACH (the Dutch national helpdesk) reported that the revision had been "postponed until after 2024" [18].
- 8 July 2025: the Chemicals Industry Action Plan (COM(2025) 530) committed to a targeted revision "to simplify the rules and speed up the procedures for industry", due in Q4 2025. Its reason was that "certain REACH processes have proven to be burdensome for companies, in particular SMEs" (COM(2025) 530, pp. 16 and 19). That deadline passed, and the April 2026 statement followed.
What had been on the table (now shelved) The Commission presented these to stakeholders at CARACAL-54 on 3 April 2025 (EP Legislative Train):
- Registrations valid for 10 years, with ECHA able to revoke them.
- Mandatory dossier updates after a substance is identified as an SVHC.
- Digital supply-chain communication and digital safety data sheets.
- EU criteria for national enforcement systems, including EU audits of Member State enforcement.
- Deletion of Annexes III and XIII, plus updates to other Annexes.
- A Mixture Assessment Factor.
- Clearer tools for the generic approach to restrictions.
None of these is law. Without a proposal, they have no timetable.
What is still changing around REACH
- New restrictions continue through the Annex XVII procedure:
- Regulation (EU) 2026/859 restricts 2,4-dinitrotoluene in articles for consumer and professional uses outside industrial sites [19].
- Regulation (EU) 2026/1168 fixes the microplastics entry (entry 78) so that its derogations for medicinal products and PPORD work as intended. The fix applies retroactively from 17 October 2023 [20].
- Restrictions Roadmap (updated 2 July 2026): 11 REACH restrictions have been adopted since 2022 and six more are near completion. Current work includes PFAS, hexavalent chromium substances and octocrylene (Commission news).
- Chemicals omnibus (COM(2025) 531): this amends CLP, the Cosmetics Regulation and the Fertilising Products Regulation, not REACH itself.
- The CLP advertising and distance-sales rules would apply only to products for the general public, on the grounds that REACH already governs information flows in professional supply chains (COM(2025) 531, p. 3).
- For fertilising products, the extended registration requirements would be removed and standard REACH rules would apply (Commission Q&A).
- Proposed ECHA Basic Regulation: this would give ECHA its own legal framework. The provisions on ECHA's governance "that are currently part of the REACH Regulation will be removed" (Commission Q&A).
- Environmental omnibus (10 December 2025): proposes repealing the SCIP database by amending the Waste Framework Directive. Its functions would move to the Digital Product Passport and the One Substance, One Assessment package (press release IP/25/2997). This doesn't change the REACH Article 7 and Article 33 duties themselves.
Approach: I searched the REACH Regulation family in the Official Journal and RIVM Bureau REACH's publications, then official Commission, Parliament and Council pages for the revision's status. I didn't find the full transcript of the 27 April 2026 ENVI hearing or any Commission statement on a replacement plan; the Commissioner's quote comes from the Parliament's Legislative Train.