REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals and is a comprehensive regulation of the European Union (EC Regulation No. 1907/2006). Its main purpose is to protect human health and the environment from risks posed by chemicals, while also enhancing the competitiveness of the EU chemicals industry. Unlike many regulations, REACH places the burden of proof on companies, requiring them to demonstrate that the substances they manufacture, import, or use are safe.
Under REACH, companies that manufacture or import chemical substances into the EU in quantities of one tone or more per year must register them with the European Chemicals Agency (ECHA). Registration requires companies to submit detailed information on the properties, hazards, uses, and safe handling of substances. This ensures that chemical risks are properly assessed and controlled throughout the entire supply chain, from raw material production to finished products.
A key component of REACH is the identification and control of Substances of Very High Concern (SVHC). These include substances that are carcinogenic, mutagenic, toxic to reproduction (CMR), persistent, bio accumulative and toxic (PBT), very persistent and very bio accumulative (vPvB), or those with equivalent levels of concern, such as endocrine disruptors. SVHCs are published in the Candidate List, which is updated regularly by ECHA. If an article contains an SVHC at concentrations above 0.1% by weight, suppliers must provide information to customers and consumers and meet notification obligations.
REACH also includes Authorisation and Restriction processes. Substances listed in Annex XIV (Authorisation List) cannot be used unless specific permission is granted, ensuring that the most hazardous chemicals are progressively replaced by safer alternatives. Annex XVII (Restriction List) limits or bans certain substances in specific applications, such as restrictions on heavy metals, solvents, and hazardous plasticizers. These measures aim to reduce exposure risks while supporting safer product design.
Overall, REACH establishes a robust chemical management framework that improves transparency, encourages substitution of hazardous substances, and promotes safer innovation. By improving communication throughout supply chains and requiring continuous risk evaluation, REACH plays a vital role in environmental protection, consumer safety, and sustainable manufacturing practices across Europe.
How to comply
To comply with REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), companies must first understand their role within the supply chain, as obligations differ depending on whether a company is a manufacturer, importer, distributor, or downstream user. This classification determines legal responsibilities, particularly for substance registration, safety assessments, and information sharing. Companies should establish internal procedures to identify their regulatory duties and assign responsibility for REACH compliance within the organisation.
A fundamental step in REACH compliance is gathering accurate material and substance data for all products and components. This includes maintaining detailed Bills of Materials (BOMs) and obtaining supplier material declarations and Safety Data Sheets (SDS). Businesses must verify whether any substances present are listed on the Substances of Very High Concern (SVHC) Candidate List, which is updated regularly by the European Chemicals Agency (ECHA). If SVHCs exceed 0.1% by weight in articles, companies must communicate this information to customers and consumers and ensure safe-use instructions are provided.
For companies manufacturing or importing substances into the EU at volumes of one tone or more per year, registration with ECHA is mandatory. This requires submitting technical dossiers that include data on the substance’s properties, hazards, exposure scenarios, and risk management measures. Downstream users must ensure that their uses of substances are covered by their suppliers’ registrations and comply with the prescribed operational conditions and risk management requirements.
REACH also requires careful monitoring of the Authorisation (Annex XIV) and Restriction (Annex XVII) lists. Substances on the Authorisation List may only be used with explicit permission from the European Commission, and their use is subject to strict control and defined sunset dates. The Restriction List limits or prohibits certain substances in specific applications, requiring companies to ensure that products placed on the market fully meet these regulatory constraints.
Finally, effective REACH compliance depends on strong documentation control, supply chain communication, and continuous regulatory monitoring. Companies must maintain comprehensive technical files, track updates to the SVHC Candidate List (typically published twice per year), and periodically review supplier compliance. By embedding REACH compliance into product development, procurement, and quality management systems, organisations can ensure long-term regulatory conformity, reduce legal risks, and promote safer and more sustainable manufacturing practices.
Latest Additions to the REACH Restriction List (Annex XVII – 2025 Update)
In August 2025, the EU adopted Regulation (EU) 2025/1731, adding 16 new CMR substances to the REACH restriction list. These substances are now banned or heavily restricted in consumer products and general-use mixtures.
Newly Restricted Substances Include:
Carcinogens (Category 1B)
- Diuron
- Tetrabromobisphenol A (TBBPA)
- N,N-dimethyl-p-toluidine
- 4-nitrosomorpholine
- 4-methylimidazole
Germ Cell Mutagen (Category 1B)
- Dimethyl propylphosphonate
Reproductive Toxicants (Category 1B)
(12 substances added – key examples:)
- Certain phosphonate esters
- Specific substituted aromatic amines
- Industrial solvents and plastic intermediates
These substances are now restricted or banned in mixtures and consumer articles, particularly in adhesives, coatings, inks, plastics, electronics, and industrial cleaners.
REACH Authorisation List (Annex XIV – Substances Being Phased Out)
The Authorisation List contains substances that cannot be used after their sunset date unless explicit authorisation is granted.
Key substance groups currently on Annex XIV include:
- Chromium trioxide
- Lead chromates
- Formaldehyde-related compounds
- Certain phthalates
- Hexavalent chromium compounds
- Trichloroethylene (TCE)
- Arsenic compounds
These substances are not outright banned, but their use is strictly controlled, time-limited, and must be justified.
Candidate List (SVHC) – Early Warning List
The SVHC Candidate List contains 240+ substances that may later become restricted or require authorisation. It includes:
- PFAS compounds
- Brominated flame retardants
- Phthalates
- Formaldehyde releasers
- Endocrine disruptors
Official Live Sources (Always Up-To-Date)
- REACH Restriction List (Annex XVII):
https://echa.europa.eu/substances-restricted-under-reach - REACH Authorisation List (Annex XIV):
https://www.echa.europa.eu/authorisation-list
REACH Compliance Checklist
- Identify Your Role
☐ Manufacturer
☐ Importer
☐ Distributor
☐ Downstream user
Your legal responsibilities under REACH depend heavily on your role in the supply chain.
- Identify Substances in Your Products
☐ Compile full material and substance information
☐ Maintain a Bill of Materials (BOM)
☐ Obtain Material Declarations from suppliers
- Check Against SVHC Candidate List
☐ Review latest SVHC Candidate List (ECHA)
☐ Confirm whether any substance exceeds 0.1% (w/w)
☐ Record all findings
- Fulfil Communication Duties
If SVHC > 0.1%:
☐ Inform customers automatically
☐ Provide safe-use instructions
☐ Respond to consumer requests within 45 days
- SCIP Database Notification (EU)
☐ Determine if SCIP notification is required
☐ Submit product data to ECHA SCIP database
☐ Maintain SCIP reference numbers
- Registration Obligations
☐ Confirm if substances exceed 1 tonne/year
☐ Ensure substances are registered with ECHA
☐ Obtain registration numbers from suppliers
- Check Authorisation List (Annex XIV)
☐ Verify if any substance is on Authorisation List
☐ Confirm valid authorisation exists
☐ Track sunset dates
- Check Restriction List (Annex XVII)
☐ Confirm no restricted uses
☐ Verify product complies with specific restrictions
- Maintain Documentation
☐ SVHC screening results
☐ Supplier declarations
☐ Test reports
☐ SCIP submissions
☐ Registration data
- Ongoing Monitoring
☐ Track SVHC updates (twice per year)
☐ Monitor regulatory amendments
☐ Review suppliers annually
