If you are one of the pigment importers in Europe buying from India, REACH decides how you can trade. When a substance arrives from outside the EU, the importer, not the Indian factory, normally carries the registration duty once the volume passes one tonne a year.
That duty can be passed to an Only Representative that the Indian maker appoints. Either route needs to be settled before the first purchase order, not after the cargo reaches the port.
Who holds the REACH registration for an Indian pigment?
Start by reading who registers under REACH. In short, there are two workable routes. You register the substance yourself, or the Indian manufacturer appoints an EU-based Only Representative who registers on its behalf and then names you as a downstream user.
The second route is covered in the REACH Only Representative. It suits buyers who want to avoid sharing commercial data with other registrants, but it also ties you to that one supplier for the registered substance.
Ask every Indian supplier in writing which route it supports. A supplier that answers with a general statement of compliance has not answered the question. Ask for the registration number or the Only Representative's name, and check it with the representative directly.
Which limits apply to pigments sold in Europe?
Registration is only the first layer. Pigments can also fall under the REACH restrictions list, under the classification and labelling rules, and under limits that apply to the end product, such as toys, food packaging, textiles or cosmetics.
Heavy metals are the usual point of difficulty. Lead, cadmium, chromium VI and mercury compounds are restricted or controlled in many end uses, and some older inorganic pigments rely on them. Heavy metal limits for dyes and pigments explains how those limits are tested and reported.
Which limit applies depends on what your customer makes with the pigment. Confirm the exact threshold with your own compliance adviser or the relevant authority, because the limit for a printing ink is not the limit for a children's toy.
What proof should an Indian pigment supplier give you?
Ask for documents that can be checked, not statements. The useful set is short:
- A safety data sheet in the current EU format, with the correct classification and the registration number or Only Representative named.
- A certificate of analysis for the actual batch, showing the colour strength, shade difference and any heavy-metal results you need.
- A written statement of the substance identity, with its Colour Index name and CAS or EC number, so that your registration covers the right material.
- Third-party test reports for restricted elements, issued by a laboratory you can verify, for the same product grade you will receive.
Where do European buyers get caught out?
The common failure is a grade change. A supplier registers or tests one grade, then ships a similar-looking grade from a different route or with a different additive package. The paperwork no longer matches the cargo.
Another problem is a trader who sells pigment made by someone else and cannot say who. If the maker is hidden, you cannot confirm the registration chain. Our note on telling a trader from a manufacturer shows how to check this before you pay a deposit.
Lastly, keep the regulatory scope clear. This article is general guidance. Confirm your obligations with the European Chemicals Agency guidance, your national helpdesk or a REACH consultant before you commit to volume.
Next step
We find and audit pigment manufacturers in Gujarat, check samples and documents, and have lots tested before they ship. If you want the supplier shortlist and the REACH route sorted out before you place an order, book a free sourcing review. You can also see the range on our chemicals sourcing page.