Compliance

REACH Regulation

EU regulation on chemical substances in products, requiring authorisation, restriction and communication of hazardous substances down the supply chain.

Aliases: REACH, Regulation (EC) 1907/2006, 化学品注册评估授权限制, 欧盟化学品法规

What REACH covers

REACH, Regulation (EC) No 1907/2006, regulates chemical substances in the EU. For a seller of finished goods the relevant parts are restrictions, the candidate list of substances of very high concern, and the duty to communicate information about those substances in articles.

It applies to substances on their own, in mixtures, and in articles. An article is an object whose shape matters more than its chemical composition, which describes most consumer products.

The three mechanisms that matter commercially

Restrictions (Annex XVII). Certain substances cannot be used above stated concentrations in specified products. A restriction breach makes the product non-compliant regardless of other certifications.

Authorisation (Annex XIV). Some substances may only be used if an authorisation has been granted. Sellers rarely hold these directly, but a supplier's use of a listed substance can block a product.

Candidate list and SCIP. Substances of very high concern are placed on the candidate list, which is updated periodically. Above 0.1 percent by weight in an article, the seller must give the recipient enough information for safe use, and notifications are made to ECHA's SCIP database for articles placed on the EU market.

Why it catches e-commerce sellers

Non-EU suppliers often answer substance questions with a generic statement that everything is compliant. That statement is not evidence. The useful artefact is a material declaration per component, ideally backed by test reports, covering substances on the current candidate list.

Textiles, plastics, coatings, solders and adhesives are frequent sources of findings. So are recycled materials, where input streams vary.

Interaction with product rules

REACH does not replace RoHS for electrical equipment, neither does RoHS cover REACH. A product can pass RoHS limits and still contain a candidate-list substance. CE marking declarations usually do not address REACH at all, and the GPSR safety file expects substance information where risks exist. Packaging is also in scope, which connects to the PPWR.

Practical approach

Build a component-level material declaration for each SKU, refresh it when the candidate list changes, and keep supplier declarations on file with a date. Two updates per year is the realistic rhythm, since the list is amended periodically.

Primary source: Regulation (EC) No 1907/2006; ECHA candidate list.

FAQ

Does REACH require registration for every product?

No. Registration applies to substances manufactured or imported above one tonne per year. For finished goods, the relevant duties are restrictions, authorisation and communication about substances of very high concern.

What is the 0.1 percent threshold?

It is the concentration above which a substance of very high concern in an article must be communicated to the recipient and notified for the SCIP database. It is measured per component, not per finished product.

Is a supplier declaration enough to prove REACH compliance?

Only if it names the substances and the basis of the assessment. A generic letter stating compliance without component-level data is weak evidence in a market surveillance or marketplace review.

Does RoHS compliance cover REACH?

[RoHS](/wiki/rohs) restricts ten substances in electrical equipment. REACH covers a far wider set and applies to non-electrical goods as well, so the two obligations are separate.

How often should I re-check the candidate list?

The list is amended periodically, usually more than once a year. Reviewing your declarations after each update is the practical way to stay current.