REACH Explained: The EU Chemicals Regulation Every Exporter Must Handle

Last time we covered RoHS. This is its big brother — REACH. If RoHS is electronics' substance blacklist, REACH is the chemicals management system for ALL products: whatever you sell in the EU, it's in scope.

What REACH is

Full title: Regulation (EC) No 1907/2006 (Registration, Evaluation, Authorisation and Restriction of Chemicals).

Note it's a Regulation, not a Directive — directly applicable across all EU member states, no national transposition. Published 2006, in force 2007, it's the cornerstone of EU chemicals law.

Four mechanisms — the name says it all

• Registration — substances manufactured or imported above 1 tonne/year must be registered with ECHA (European Chemicals Agency) with safety data.
• Evaluation — ECHA reviews registrations; suspicious dossiers get flagged for further testing.
• Authorisation — substances of very high concern listed in Annex XIV can't be used without authorisation ("apply to keep using, on a sunset schedule").
• Restriction — Annex XVII lists restricted substances and uses (the well-known ones: phthalates, azo dyes...).

What exporters must watch: the SVHC list

SVHC (Substance of Very High Concern) is REACH's moving red line:

• ECHA updates the candidate list regularly — currently over 240 entries
• Familiar ones: certain phthalates, lead compounds, specific flame retardants, sensitizing dyes...
• Rolling additions — a formula that passed last year can fail this year's list

What happens above 0.1% (Article 33)

The regulation is explicit: when an article contains an SVHC above 0.1% (w/w), the supplier must:

1. Provide the recipient (downstream business) with information allowing safe use
2. Answer consumer requests within 45 days, free of charge
3. Since 2021, submit a notification to ECHA's SCIP database

SVHC above 0.1% isn't an automatic sales ban (unless it's also on the restriction list, Annex XVII) — but the information duties are non-negotiable. Hiding it risks fines and market-access enforcement.

RoHS vs REACH (30-second version)

Both apply — no single report covers both.

Exporter's practical checklist

1. Screen against the latest SVHC list — 240+ entries now; don't test against a three-year-old version.
2. Collect SVHC declarations from your supply chain — together with RoHS material reports, one collection for both.
3. Above 0.1%: do the information duties — prepare safe-use information and SCIP notification; don't gamble on enforcement.
4. Watch Annex XVII restrictions — category-specific bans (phthalates in toys, azo dyes in textiles) are hard bans, far more serious than SVHC information duties.

The CE connection

REACH sits outside the CE marking directives (it's a standalone regulation), but market surveillance checks it alongside CE. The complete EU export set: CE (product safety) + RoHS (EEE substances) + REACH (chemicals) + product-specific rules (Battery Regulation, Toy Safety Directive, etc.).

The full REACH text (Article 33 duties, Annex XVII restrictions) is in the StdFlow knowledge base — sign up at stdflow.com and ask an AI agent for the original text, every answer cited.