REACH is Regulation (EC) No 1907/2006, the EU's main law on chemicals. For an importer, its core rule is simple: a substance made in or imported into the EU at 1 tonne or more a year must be registered with the European Chemicals Agency (ECHA) before it is placed on the market.
The name stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It applies across the EU and the wider European Economic Area, which adds Norway, Iceland and Liechtenstein. Northern Ireland also stays under EU REACH.
What the four parts mean for you
- Registration means someone in the EU submits a dossier on the substance's properties, uses and risks. The data required grows with the tonnage band: 1 to 10, 10 to 100, 100 to 1,000, and 1,000 tonnes or more a year.
- Evaluation means ECHA and member states check dossiers and can ask for more tests.
- Authorisation applies to substances of very high concern listed in Annex XIV. These cannot be used in the EU after their sunset date without a specific authorisation.
- Restriction means Annex XVII limits or bans certain substances in certain uses, whoever registered them.
How it applies to an imported product
REACH counts substances, not products. If you import a pure chemical such as a dye intermediate, that substance needs a registration covering your tonnage. If you import a mixture, such as a formulated textile auxiliary, each substance in it counts separately. Your 10 tonnes of product might contain 3 tonnes of one substance and 7 of another, and each needs cover.
Polymers are exempt from registration themselves, but the monomers they are made from usually are not. Articles, such as finished goods, have their own rules: you must notify and inform customers if they contain candidate-list substances above 0.1% by weight.
The EU importer is the legal party responsible. An Indian supplier cannot register directly because it is not established in the EU. Either you register, or the supplier appoints an Only Representative to register on its behalf. Who does what is covered in who is responsible for REACH registration.
What to ask an Indian supplier
Before you place a first order, ask these questions in writing. The answers tell you whether you can legally import the product at all.
- Is each substance in the product already registered, and by whom: an Only Representative, another importer, or nobody?
- Does the registration cover your tonnage band and your intended use?
- Will the supplier give you the registration number and a letter confirming you are covered as an importer under its Only Representative?
- Is any substance on the candidate list of substances of very high concern, or restricted under Annex XVII?
- Can the supplier provide an SDS in REACH format, in the language of the country you sell in?
Who is responsible, and how to check
Compliance sits with the EU legal entity that places the substance on the market, not with the factory in Gujarat. Customs may not stop a non-compliant shipment at the border, but national enforcement authorities can stop sales and fine the importer later.
Check registrations yourself in ECHA's public database of registered substances, searching by CAS or EC number. For anything you are unsure of, confirm with ECHA's guidance, your national REACH helpdesk or a regulatory consultant before you commit to volumes.
Next step
We check what a supplier says about REACH against the registration record and the documents, before you pay a deposit. To review a product you want to bring into the EU, book a free sourcing review.