Q.01

What is a REACH certificate?

REACH has no official "REACH certificate." Regulation (EC) No 1907/2006 does not provide for any certificate. ECHA, the EU agency that runs REACH, issues a registration number. The documents traded as "REACH certificates" are things suppliers write themselves, or third-party test reports. None of them is issued by ECHA, and none of them replaces a legal duty.

What REACH actually gives you: a registration number

  • Article 5 ("No data, no market"): substances on their own, in mixtures or in articles "shall not be manufactured in the Community or placed on the market unless they have been registered" where registration is required [1].
  • Article 6: a manufacturer or importer of a substance at "one tonne or more per year shall submit a registration to the Agency," and must pay the fee with it [2].
  • Article 20:
    • ECHA first assigns a submission number.
    • It then runs a completeness check. That check "shall not include an assessment of the quality or the adequacy of any data". An incomplete registration that the registrant fails to complete by the deadline is rejected.
    • Once the registration is complete, ECHA "shall assign a registration number" and a registration date, and tell the registrant [3].

So the official proof is the registration number for a specific substance, held by a specific registrant. Even that number only shows the dossier was complete. It does not show ECHA judged the data adequate.

What people usually mean by a "REACH certificate"

  1. A supplier's declaration of conformity (a "REACH compliance statement"). This is a letter from the supplier saying its product meets REACH. It is self-declared.
  2. A statement about SVHCs in articles (Article 33). Suppliers often send this to meet Article 33. SVHCs are the substances of very high concern on ECHA's Candidate List. Where an article contains one above 0.1 % w/w:
    • the supplier "shall provide the recipient" with enough information for safe use, including at least the substance name;
    • a consumer who asks "shall" receive the same information, free of charge, within 45 days [4].
  3. Lab test reports. Labs issue these to show SVHC content, or compliance with an Annex XVII restriction, for a tested sample. They are commercial reports, not regulatory approvals.

What to ask a supplier for instead

  • For substances or mixtures: the registration number of each relevant substance, plus the safety data sheet. The Commission's Your Europe page says registrants must use a safety data sheet to tell users down the supply chain about risk management measures (Your Europe).
  • For articles: a dated Article 33 statement checked against the current Candidate List.

The Commission's REACH explained page also contains nothing on any certificate or certification scheme.

Approach: I read Articles 5, 6, 20 and 33 of the current consolidated REACH Regulation, plus the Commission's REACH pages on Your Europe and its Single Market site. ECHA's own registration pages would not open this time.

Q.02

What should a supplier REACH declaration contain?

REACH does not prescribe a "supplier REACH declaration". No article sets its format or content, so a useful one is built around the information duties the Regulation actually places on suppliers. Which duties apply depends on what is being supplied: a substance or mixture, or an article.

1. Substances and mixtures

  • Where a safety data sheet is required: the safety data sheet itself is the legal deliverable, and a declaration cannot replace it. The supplier "shall provide" a safety data sheet compiled under Annex II when:

    • the substance or mixture meets the CLP criteria for a hazardous classification;
    • the substance is PBT or vPvB; or
    • the substance is on the Candidate List [5].

  • Updates to the safety data sheet: these must name the registration number once the substance is registered. They must also be updated "without delay" when any of these happens: new hazard or risk-management information comes in, an authorisation is granted or refused, or a restriction is imposed [6].

  • Where no safety data sheet is required: Article 32 is the closest REACH comes to listing what a declaration must contain. The supplier "shall provide":

    • (a) the registration number(s), if available;
    • (b) whether the substance is subject to authorisation, with details of any authorisation granted or denied in that supply chain;
    • (c) details of any restriction under Title VIII;
    • (d) any other available, relevant information needed for appropriate risk management measures.

    This information must be supplied free of charge, on paper or electronically. It must be updated on the same three triggers as above and re-sent to everyone supplied in the preceding 12 months [7].

2. Articles

  • Candidate List substances (Article 33): for any substance on the Candidate List present above 0.1 % w/w, the supplier "shall provide" enough information for safe use, "including, as a minimum, the name of that substance." A consumer who asks must get the same information free of charge within 45 days [4].
  • Restrictions (Annex XVII): a substance in an article that is covered by an Annex XVII restriction "shall not be manufactured, placed on the market or used unless it complies with the conditions of that restriction" [8]. A credible declaration therefore states compliance entry by entry, not in a blanket sentence.
  • Notification (Article 7(2)): producers and importers must notify ECHA of a Candidate List substance that is above 0.1 % w/w and present at more than one tonne per producer or importer per year. Notification is not required where exposure can be excluded; in that case they "shall supply appropriate instructions to the recipient" [9]. Asking the supplier to confirm its Article 7 position, where relevant, is worthwhile.
  • SCIP (Waste Framework Directive, not REACH): Article 9(1)(i) of Directive 2008/98/EC requires any supplier of an article to send its Article 33(1) information to ECHA as from 5 January 2021. That submission goes into the database ECHA maintains under Article 9(2), known as SCIP [10]. A SCIP notification number is a sensible item to request.

3. Practical elements that make a declaration usable

These are good practice, not legal requirements:

  • Identification: the product or article, part numbers, supplier legal entity and the signatory.
  • Date and Candidate List version: a date of issue, and the version of the Candidate List it was checked against, given by date or number of entries. The list changes often. The latest inclusion decision I found is D(2025)7771-DC of 4 February 2026, which added 11 entries including n-hexane and Bisphenol AF and its salts [11]. It followed decisions dated 21 January 2025, 25 June 2025 and 5 November 2025 [12][13][14]. A declaration dated before February 2026 does not cover those substances.
  • Concentration basis: for complex articles, state the basis the 0.1 % was calculated on (per article or per component).
  • Annex XIV: a statement on authorisation status for any Annex XIV substance used.
  • Evidence: how compliance was established (test data, supplier chain declarations, material composition) and a commitment to update the declaration.

Approach: I read Articles 7, 31, 32, 33 and 67 of the current consolidated REACH Regulation, Article 9 of the consolidated Waste Framework Directive, and ECHA's Candidate List inclusion decisions from 2025 onward.

Q.03