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Which EU rules apply when you import a tonne or more of a substance a year?

A substance imported from outside the EU at one tonne or more a year: who carries the registration duty and what else still applies. This page is one fixed set of answers to the product check, written out in full. The wording comes from the same rule set the questionnaire uses, so the two cannot drift apart.

Triage, not a clearance. It sorts this situation into the right regimes; it does not classify your specific product, and classification is where most of the cost sits. Your own case may differ on any of the answers below; run the check with your own.

The answers this rests on

Open the check with these answers →

3 regimes apply to this situation

REACHregistration duty

At one tonne or more per legal entity per substance per calendar year, the importer carries the registration duty; unless your non-EU supplier has appointed an Only Representative, in which case you are a downstream user and the duty is theirs.

  • Ask your supplier in writing whether an Only Representative is appointed, and for its registration number.
  • There is no such thing as a REACH certificate; every document with that name is a supplier self-declaration.
  • From 5 February 2027 a reduced SME fee needs ECHA's recognition decision handed in with the submission; self-declaring your company size at submission stops working. Apply for that recognition at least two months before you submit, because ECHA then has two months of its own to decide once it holds all the documents. A recognition is valid for three years, so plan the first one well ahead of the dossier.
Regulation (EC) No 1907/2006, Articles 6, 3(11) and 3(14); fees and SME recognition: Regulation (EC) No 340/2008, Article 13(1) for the two-month application deadline and Article 13(4) for ECHA's own two months, both as replaced by Commission Implementing Regulation (EU) 2025/2067, Article 1(2), which applies from 5 February 2027 under its Article 3 · 1907/2006 on EUR-Lex · 2025/2067 on EUR-Lex · read the full answer

EPR; extended producer responsibilityif packaging comes with it

If any packaging accompanies these goods; including transport and industrial packaging, which most member states count; you are the producer of that packaging in every country where you first place it on the market. For genuinely unpackaged bulk, check before assuming it applies. There is no EU-wide register: each state has its own scheme, number, fee and report.

  • Packaging triggers it on its own; pallets, drums, wrapping and liners included in most states.
  • You named 1 member state; that many separate registrations, each with its own register, number and fee.
  • Register before the first sale into that country; several states treat selling without a number as an offence.
  • From 12 August 2026, if you make packaging or packaged products available for the first time in another member state directly to end users, you must appoint an authorised representative for extended producer responsibility there, by written mandate and per country. Sell to a distributor established in that country instead and he is the producer there, not you.
  • That first rule already covers you if you sit outside the EU and supply end users directly: Article 3(1), point (15)(c) and (d) says established in a member state or in a third country. Only if you sell to a distributor in that country instead is the mandate a member-state option rather than a duty.
National EPR regimes implementing Directive 2008/98/EC, Article 8a; Regulation (EU) 2025/40 (packaging), Article 45(3) read with Article 3(1), point (15)(c) and (d), and Article 71 (applies from 12 August 2026) · 2025/40 on EUR-Lex · read the full answer

Sanctions screeningscreen before you pay

EU sanctions prohibit making funds or economic resources available to listed persons, directly or indirectly. There is no turnover threshold, a breach does not require intent, and a new or non-EU counterparty is exactly where this bites.

  • Screen the name free on this site before you pay an invoice.
  • Ownership above 50% by a listed person catches a supplier that is not itself listed.
  • Your bank's screening is not your screening, and it is not a defence.
  • If you may have to show later that you checked, keep a dated record naming the list versions.
Regulation (EU) 269/2014 Article 2 and equivalents; Directive (EU) 2024/1226 · 269/2014 on EUR-Lex · read the full answer

This is the list of things to check, not a clearance. It leaves out CE, RoHS/WEEE, EUDR, food and cosmetics law and customs. Something wrong or missing? Corrections are made with the source noted.

What to do next, in this order

  1. Check the counterparty exists and who may sign find the company in its home register, free
  2. Screen the name against nine sanctions lists before you pay, not after
  3. Pin down the goods code duty, CBAM scope and restrictions all hang off it
  4. Work out duty and VAT you bring the TARIC rate, the tool does the arithmetic
  5. Verify the VAT number on the day you invoice VIES, and keep the response

Where each of these is worked out

Does this not fit your case, or is something missing? Ask it here; questions are answered with the regulation and the article, and the questionnaire gets fixed. Providers who do this work are listed separately; being named there is not a recommendation.

Other situations, worked out the same way

What this does not cover

Named, because a triage tool that stays quiet about its edges is worse than none: