REACH for importers, answered
REACH is the rule people ask about most and understand least. The single most common misunderstanding is in the question itself: do you have REACH? There is no such thing to have. What exists is a registration obligation that falls on a specific company, for a specific substance, above a specific tonnage; and knowing whose obligation it is decides who pays.
This is a reference built from published regulation and official guidance, not legal advice. Rules change and national implementation differs. Every answer carries the source and the date it was last checked, so you can verify it yourself before you act on it.
What REACH is, and what it is not
Is there such a thing as a REACH certificate? no
No. ECHA does not issue certificates, approvals or conformity statements of any kind. There is no accreditation body, no stamp, and no certificate number you can look up. Every document you have ever been sent called a "REACH certificate" was written by the supplier or their consultant, about themselves.
Full answer — the grounds, the numbers, the pitfalls
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.
Common mistake: accepting a PDF headed "REACH Certificate" as proof and stopping there. It is a self-declaration. If registration matters for your cargo, ask for the registration number and check it.
How do I check whether a substance is really registered? verifiable
Ask for the registration number and look it up in ECHA's public database of registered substances. A registration number runs in the form 01-XXXXXXXXXX-XX-XXXX. If a supplier cannot produce one for a substance that needs registering, that is the answer to your question.
Full answer — the grounds, the numbers, the pitfalls
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.
Whose obligation is it; mine or my supplier's? usually yours
If you import into the EU from outside it, the obligation is yours. A non-EU manufacturer has no duties under REACH at all; the duty falls on the EU importer, unless the manufacturer has appointed an Only Representative established in the EU who takes it over.
Full answer — the grounds, the numbers, the pitfalls
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.
Common mistake: assuming a supplier's declaration transfers the obligation. It does not. Only an appointed Only Representative changes who is responsible, and you should see the appointment.
Waste, recovered substances and the exemption most people miss
My material is waste. Does REACH apply? not while it is waste
No. Waste is not a substance, mixture or article under REACH, so the regulation does not apply to it while it remains waste. The moment it ceases to be waste, that changes: the recovered material is a substance, and someone becomes its manufacturer.
Full answer — the grounds, the numbers, the pitfalls
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.
Common mistake: treating end-of-waste as the finish line. It is a change of regime, not an exit from regulation, and the second regime has its own registration question.
I recover a substance from waste. Am I exempt from registration? conditionally
Possibly, under the recovered-substance exemption; but it is conditional, and both conditions have to hold. The substance recovered has to be the same as one already registered by someone else in the EU, and you have to have the information needed for safe use available to you.
Full answer — the grounds, the numbers, the pitfalls
The two conditions, because they are usually quoted as one:
- 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.
- 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.
Common mistake: assuming that because the input was waste, the output is outside REACH. Once it is no longer waste, it is a substance, and you made it.
Source: Regulation (EC) No 1907/2006, Article 2(7)(d) and Annex V; ECHA guidance on waste and recovered substances.
Checked: 3 September 2026.
What it costs, and what you actually have to produce
What does registration cost, and how long does it take? months, not weeks
The fee depends on the tonnage band and on whether you qualify as an SME; the timeline depends almost entirely on whether a joint submission already exists for your substance. Joining an existing one is a matter of months. Being the first is a matter of years.
Full answer — the grounds, the numbers, the pitfalls
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.
Common mistake: budgeting the ECHA fee and forgetting the data. Access to the study data behind a joint submission is usually the larger number, and it is negotiated with the existing registrants rather than paid to ECHA.
Source: Commission Implementing Regulation on fees under REACH, as amended with effect from 5 November 2025; ECHA guidance on SME verification from 5 February 2027; Commission Recommendation 2003/361/EC (SME definition). Checked: 3 September 2026.
Is a safety data sheet the same as REACH compliance? no
No, but they are connected. The safety data sheet is how information travels down the supply chain, and REACH prescribes its content and format. Having one does not prove a substance is registered, and a registration does not produce one automatically.
Full answer — the grounds, the numbers, the pitfalls
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.
The part that catches finished goods, not chemicals
Everything above is about substances. Most importers never buy a substance; they buy an article that contains one, and the three duties below are the ones that actually reach them. They apply whether or not anybody in your chain has ever filed a registration.
My supplier says the goods are "SVHC-free". What does that mean, and what do I have to pass on? 0,1 % w/w
"SVHC-free" is not a legal status; it is a claim about the candidate list on the day it was written. What the law requires is this: if an article you supply contains a candidate-list substance above 0,1 % by weight, you must give your business customers enough information for safe use, as a minimum the name of that substance, and give a consumer the same within 45 days of a request, free of charge. Separately, the same information goes to ECHA's SCIP database.
Full answer — the grounds, the numbers, the pitfalls
Four things decide whether this lands on you:
- The threshold is per constituent article, not per finished product. The Court of Justice decided this in 2015: where a product is made up of several articles, the 0,1 % is calculated on each constituent article, not on the assembly. A cable, a screw, a coating and a housing are each measured on their own. This is why "0,08 % of the total weight" is usually the wrong calculation.
- The candidate list grows. It is updated by ECHA, normally twice a year. A declaration written before an update is out of date the day after it, which is why an undated "SVHC-free" letter is worth nothing.
- There is a second, heavier duty above one tonne. A producer or importer of articles must notify ECHA where a candidate-list substance is present in those articles above 0,1 % w/w and in quantities totalling over one tonne per importer per year. It does not apply where you can exclude exposure during normal or reasonably foreseeable use including disposal, and in that case you supply appropriate instructions to the recipient instead.
- SCIP is a separate filing. Since 5 January 2021 any supplier of an article containing a candidate-list substance above 0,1 % w/w has to provide the Article 33(1) information to ECHA. That obligation sits in the waste directive, not in REACH, which is why it is so often missed.
What to ask a supplier instead of "is it SVHC-free": which candidate-list version did you check against, on what date, and per which article of the assembly? A supplier who can answer that has done the work; one who sends a certificate has not.
Common mistake: treating the candidate list as a ban list. Being on it triggers information duties, not a prohibition. What actually bans substances in products is the restriction list, below.
Source: Regulation (EC) No 1907/2006, Article 33 (duty to communicate information on substances in articles; 0,1 % w/w, 45 days, free of charge) and Article 7(2) and (3) (notification to the Agency above one tonne per importer per year, and the exposure-exclusion carve-out), with Articles 57 and 59(1) and (10) on the candidate list; Court of Justice, Case C-106/14, judgment of 10 September 2015 (the 0,1 % is calculated per constituent article, not per assembled product);
Directive 2008/98/EC, Article 9(1)(i) (SCIP notification to ECHA as from 5 January 2021).
Checked: 5 September 2026.
Which substances are simply not allowed in my product? Annex XVII
The restriction list. A substance on its own, in a mixture or in an article for which Annex XVII contains a restriction may not be manufactured, placed on the market or used unless it complies with the conditions of that restriction. This is the part of REACH that most consumer goods actually fail on, and unlike registration it applies to you the moment you place the goods on the market.
Full answer — the grounds, the numbers, the pitfalls
Annex XVII is a numbered list of entries, each naming a substance or group and the products and conditions it is restricted in. It changes several times a year by Commission regulation. The entries that catch imported consumer goods most often, by product type rather than by number:
- Jewellery, zips, fasteners and small metal parts; lead, cadmium and nickel release limits, with nickel measured as release in prolonged skin contact rather than as content.
- Toys and childcare articles; phthalates, with separate entries for the plasticised material and for articles that can be placed in the mouth.
- Textiles, leather and clothing; azo dyes that release listed aromatic amines, and the CMR entry covering substances classified carcinogenic, mutagenic or toxic for reproduction in clothing and footwear.
- Rubber and plastic parts with prolonged skin contact; polycyclic aromatic hydrocarbons, which is why tool grips, sports equipment and cables fail.
Three practical consequences. Restrictions are drafted per product use, so the same substance can be lawful in one article and unlawful in another. They apply to placing on the market, so goods already in your warehouse are caught by an entry that starts applying while they sit there, unless the entry says otherwise. And enforcement is by testing: this is the part of REACH that market surveillance actually samples for, and the Safety Gate alerts are full of it.
Common mistake: reading a supplier test report for the wrong entry. A phthalate report says nothing about azo dyes; a lead-content report says nothing about nickel release. Match the report to the entry that applies to the article.
Source: Regulation (EC) No 1907/2006, Article 67(1) (nothing may be manufactured, placed on the market or used contrary to a restriction) and Annex XVII (the restriction entries themselves); the current entries and their conditions are published by ECHA and amended by Commission regulation.
Checked: 5 September 2026.
Authorisation: when may a substance not be used at all any more? Annex XIV
Once a substance is listed in Annex XIV it may not be placed on the market for a use, or used, after its sunset date unless an authorisation has been granted for that use or an exemption applies. It is the heaviest instrument in REACH, and it is also the one that usually does not reach an importer of finished goods directly.
Full answer — the grounds, the numbers, the pitfalls
The distinction that matters for an importer:
- Authorisation bites on use and on placing on the market for a use inside the Union. A European manufacturer who wants to keep using a listed substance has to hold an authorisation for that use, or stop on the sunset date.
- Restriction, not authorisation, is what reaches imported articles. This is the asymmetry the system is often criticised for: the same substance can be prohibited for an EU producer and still arrive inside an imported article, until a restriction closes it.
- Where it does reach you is upstream: if a substance you buy, or that your EU supplier uses to make what you buy, is heading for Annex XIV, your supply stops on a date that is published years in advance. The list moves from the candidate list, so the candidate list is also your early warning system.
How to use it: take the candidate list and the authorisation list once a year, check them against the substances your suppliers declare, and note the sunset dates of anything you find. That is a half-day of work that shows you which supply lines have an expiry date.
Source: Regulation (EC) No 1907/2006, Article 56 (general provisions on authorisation), Article 57 (substances that may be included in Annex XIV), Article 58 (inclusion, with sunset dates) and Annex XIV.
Checked: 5 September 2026.
Who can do this for you
The answers above tell you what the rule requires. This section lists the companies that carry it out; Only Representatives, registration consultants, testing laboratories and safety data sheet authors; with what each one covers and where they are established.
This is a map built from what these companies publish about themselves, not a recommendation and not a client list. Naming a company here says nothing about whether we have worked with them.
Every entry in the tables below is editorial and unpaid. Extended (paid) listings are marked as such, sit at the top of their group, and never appear inside an answer.
How listings work.
Only Representatives and registration consultants
A manufacturer outside the EU cannot register. An Only Representative established in the EU registers in its place, and that is the only arrangement that moves the obligation away from the importer. These companies take that role and prepare the dossier that goes with it.
Testing houses with a REACH practice
Registration needs data, and data needs a laboratory. These are the large testing and certification groups that run a REACH practice next to the testing itself.