To know how to do REACH registration as an importer, follow the order below. REACH registration requirements apply to a substance you import into the EU or EEA at one tonne or more a year, per legal entity, with limited exemptions. You register before the first import, since the rule is no data, no market.
This is a practical outline, not legal advice. Check the current text and guidance on the ECHA website, and consult a specialist for your substance.
Step 1: confirm that you must register
First check whether the substance is on its own, in a mixture or in an article that releases it, whether it is exempt, and whether you are the party who must register. The question of importer or supplier is covered in who registers under REACH. A non-EU manufacturer cannot register directly and may appoint an EU Only Representative, in which case you become a downstream user; see the REACH Only Representative.
Step 2: identify the substance and tonnage band
Define the substance by name, EC and CAS numbers and composition, including impurities and additives. Then estimate the quantity you will import each year. The tonnage band sets the data you must provide: from one tonne up, then ten, one hundred and one thousand tonnes per year. Higher bands need more testing data. Ten tonnes and above also require a chemical safety report.
Step 3: join the data and get access
If the substance is already registered, you submit a joint registration with the lead registrant. You request access to the shared data, usually under a letter of access that is negotiated with the lead registrant, who passes on a share of the data costs. If it is not registered, you must make an inquiry to ECHA first.
The old pre-registration route closed years ago, so for a new substance expect to be the lead or to start a new group. Data sharing is required by law, and it also avoids repeating animal tests.
Step 4: prepare and submit the dossier
The dossier is built in IUCLID software and submitted through the ECHA portal. Contents include substance identity, classification, uses, exposure information and test data for your tonnage band. The registration fee depends on tonnage and company size; ECHA publishes the current fee schedule. After a completeness check you receive a registration number and can import.
Who pays and what comes after?
The registrant pays: the ECHA fee, the data access cost and any consultant or testing cost. Costs vary widely by substance and band, so plan with a specialist before agreeing a supply contract. After registration, keep the dossier current, update the volume band if you exceed it, and pass safety information down the supply chain. UK REACH is separate and needs its own registration; see UK REACH and EU REACH. For the overview, read what EU REACH requires.
Do not leave the safety data sheet and classification until last. They flow from the registration data, and your downstream customers will ask for them. Ask your supplier early for the information you will need to describe the substance accurately, such as composition, impurities and uses, so the dossier is not delayed by missing data. A registration built on a vague composition is a common reason for questions from the authority later.
Next step
We can ask your Indian manufacturer for composition and data, and check whether it already works with an Only Representative. To plan your imports, book a free sourcing review.