Does REACH apply when you sell goods and substances into the EU from outside it, and your EU customer imports them?

You sell from outside the Union, so the registration duty falls on whoever imports: your EU customer. Appointing an Only Representative lifts that duty from every one of your EU customers at once, which makes it a selling point rather than a cost. Ask your EU supplier for the registration number behind the substance; he has it, and you may be asked for it. There is no such thing as a REACH certificate; every document with that name is a supplier self-declaration. Source: Regulation (EC) No 1907/2006; Articles 6, 3(11) and 3(14).

Does Sanctions screening apply when you sell goods and substances into the EU from outside it, and your EU customer imports them?

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. Source: Regulation (EU) 269/2014 Article 2 and equivalents; Directive (EU) 2024/1226.

Home › Product check › Selling into the EU while your customer imports

Which EU rules apply when your EU customer is the importer?

Selling into the EU while your customer imports: which duties fall on him, which documents he will demand from you, and why. 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

What are you bringing into the EU? Consumer goods; Chemical substances or mixtures
Where does it come from? Outside the EU
Who places it on the EU market? My EU customer imports it
Who do you sell to? Businesses only
Do you sell via marketplaces? Only my own shop or direct B2B
Is any supplier or customer new to you, or outside the EU? Yes

Open the check with these answers →

3 regimes apply to this situation

REACHyour EU buyer registers

You sell from outside the Union, so the registration duty falls on whoever imports: your EU customer. Appointing an Only Representative lifts that duty from every one of your EU customers at once, which makes it a selling point rather than a cost.

Ask your EU supplier for the registration number behind the substance; he has it, and you may be asked for it.
There is no such thing as a REACH certificate; every document with that name is a supplier self-declaration.

Regulation (EC) No 1907/2006; Articles 6, 3(11) and 3(14) · 1907/2006 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

You are not the one placing it on the marketyour buyer carries it

Most duties above fall on whoever places the goods on the EU market, which is your EU customer. That does not make you free of them commercially: your buyer will ask you for the documents that let them comply, and a supplier who cannot produce them loses the order.

Expect to be asked for substance data, test reports, a declaration of conformity and the manufacturer details.
Appointing an Only Representative removes the REACH registration duty from every one of your EU customers at once; it is a selling point.

The duties follow the economic operator placing the product on the market · 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

Check the counterparty exists and who may sign find the company in its home register, free
Screen the name against nine sanctions lists before you pay, not after
Pin down the goods code duty, CBAM scope and restrictions all hang off it
Work out duty and VAT you bring the TARIC rate, the tool does the arithmetic
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:

CE marking and the product directives; machinery, toys, low voltage, EMC, PPE, radio equipment.
RoHS and WEEE; substance restrictions and take-back for electrical equipment, separate from the EPR registration above.
EUDR; for cattle, cocoa, coffee, palm oil, rubber, soy and wood and products made from them.
Food, feed, cosmetics and medical devices; each with its own approval, labelling and notification route.
Customs, origin and duties; tariff classification, preferential origin, anti-dumping measures.