REACH for importers, answered

That does not make such a document worthless — a supplier declaration is a statement they can be held to. But it is worth being precise about what you are holding:

• A supplier declaration says the supplier believes their material meets the requirements. Its value is exactly the credibility of the supplier.
• A registration number is different: it is evidence that a specific substance was actually registered with ECHA, and it can be checked.
• An SVHC statement is narrower again — it addresses whether substances of very high concern are present above 0.1% by weight, and says nothing about registration.

When a counterparty asks whether you "have REACH", they usually mean one of these three. Asking which one turns a vague exchange into a short factual one.

Two things worth knowing before you draw a conclusion from what you find:

• A registration is per substance, per legal entity. A group company being registered does not cover the entity on your invoice. This is the most common reason a number "looks wrong" when it is in fact simply somebody else's.
• A dossier can be inactive or ceased. A company that stopped manufacturing may have ended its registration; the number then still exists historically but no longer covers current supply.

When a number does not check out, the useful next question is not accusatory: ask which legal entity holds the registration and for which tonnage band. Nine times out of ten that resolves it.

That single sentence resolves most of the confusion in supplier correspondence. Your Chinese or Indian supplier genuinely does not have a REACH obligation. Someone in the EU does, and by default that is you.

The threshold is one tonne per substance, per legal entity, per calendar year. Not per shipment and not per product line — substances are counted together across the year.

If the manufacturer appoints an Only Representative, that EU-established party takes on the registration duties and the importers behind them count as downstream users instead. That arrangement has to actually exist and be documented; being told one is "being arranged" is not the same thing.

This is where two bodies of law hand over to each other, and the handover point is end-of-waste. Before it, the waste rules govern the material and REACH does not. After it, REACH governs the substance and the waste rules do not.

For anyone recovering material this has a consequence that arrives later than expected: achieving end-of-waste status is not only a relief, it is also the moment a REACH obligation begins. A recovery operator who has spent a year arguing that their output is a product should be ready for what a product brings with it.

The two conditions, because they are usually quoted as one:

1. Sameness. What you recover has to be the same substance as one that is already registered. That is a technical judgement about your actual output, not about the category it belongs to.
2. Information. The safety information required for the supply chain has to be available to you — typically because it exists in that registration and you can access it.

You do not apply for this exemption and nobody grants it. You rely on it, and you have to be able to justify it with documentation if an authority asks. That asymmetry catches people out: there is no approval to point at afterwards, only the file you should have built beforehand.

And note who this makes a manufacturer. An operator who recovers substances by chemical means — pyrolysis, for example, producing oil and recovered carbon black — becomes a manufacturer of those substances under REACH, with the duties that follow. The recovery route does not exempt you from being a duty holder; it only offers a possible route out of one specific obligation.

The two things that decide it:

• Tonnage band. Fees step up across 1–10, 10–100, 100–1000 and over 1000 tonnes per year. The data requirements step up with them, and the data usually costs more than the fee.
• Joint submission or lead. Joining an existing joint submission for a substance in a lower band is realistically a 3 to 6 month project. Building a new dossier as lead registrant in a high band runs to 18–36 months and beyond.

Two changes worth having in your calendar:

• Fees rose by 19.5% on 5 November 2025. Older quotations are out of date.
• From 5 February 2027, SME status is verified in advance. An SME wanting the reduced fee — the reduction runs from 30% to 95% — has to obtain recognition from ECHA at least two months before any fee-bearing submission. The decision then holds for three years. If you are planning a registration for 2027, the SME recognition is the step that has to start first.

What an SDS is good for, and what it is not:

• It carries the safety information that the supply chain needs, in a prescribed sixteen-section format.
• Section 15 is where regulatory information sits, and a registration number often appears in section 1 or 3 — which is why an SDS is a sensible first thing to ask for.
• It is written by the supplier. An SDS with no registration number for a substance that needs registering is not a compliant document, but it will still look like one.

For a buyer the practical order is: ask for the SDS, read section 1 and 3 for a registration number, then check that number. The document points at the evidence; it is not the evidence.