EU REACH – Registration, Evaluation, Authorisation and Restriction of Chemicals

Note that this information from the Department for Business and Trade (DBT) should not be taken as legal or compliance advice. Seek independent advice based on your personal operational requirements.

Overview

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is the EU’s main regulation for managing chemical substances:

EU REACH aims to protect human health and the environment from chemical risks and promote competitiveness within the EU chemicals industry. It applies to chemical substances including those used in a mixture such as cleaning agents and paints or in an article such as clothing, and electronics.

EU-based businesses which manufacture or import chemical substances in quantities of more than one tonne per year must register those substances with the European Chemicals Agency (ECHA).

Why it matters

The purpose of REACH is for the EU to:

  • ensure early identification and control of hazardous substances
  • ensure industry and producer responsibility, enforcing risk management and transparency across supply chains
  • empower consumers with the right to know about harmful chemicals in products
  • support environmental sustainability and aligns with EU goals like the Green Deal and zero pollution

Who should comply

EU REACH affects a wide range of actors:

  • manufacturers: producing chemicals within the EU
  • importers: bringing chemicals, mixtures, or products into the EU
  • distributors: storing and selling chemicals within the EU
  • downstream users: using chemicals within the EU in industrial or professional activities

Manufacturers and Importers have registration duties under EU REACH if they manufacture or import less than one tonne per year. If a business is already supplying a chemical to an EU importer, that importer should already have registered the substance with ECHA.

EU Manufacturers, Importers or Downstream users can all apply for authorisation to use or place on the market chemicals which are on Annex XIV of EU REACHopens echa.europa.eu in a new tab (the authorisation list).

All EU actors are subject to the restrictions on Annex XVII of EU REACHopens echa.europa.eu in a new tab.

GB companies do not have compliance duties under EU REACH.

Impact for GB Exporters (SMEs)

Registration

It is the responsibility of EU-based customers to ensure that the chemicals or products they are importing into the EU contain are registered under EU REACH. To this end they may look to their GB suppliers for information which enables them to comply, e.g. the ingredients of a mixture.

Alternatively, the GB SME can appoint an EU-based Only Representative (OR) to handle registration on their behalf. This removes the duty to register from the EU importers in the supply chain. An OR may be appointed to keep the formulation of a mixture confidential, or to supply to new customers. Only Representatives are often consultancy firms and will expect the GB company to work with them to enable them to comply, typically as a condition of accepting the business.

Substances which are on Annex XVII of EU REACH are restricted and cannot be imported into the EU.

Authorisation

Authorisation applies to chemicals that have been identified as substances of very high concern (SVHCs) and added to Annex XIV of EU REACH. These chemicals can only be used or placed on the market where they have been authorised. The responsibility to apply for an authorisation under EU REACH lies with the EU manufacturer, importer or downstream user.

However, EU customers may still require their GB suppliers to inform them of any SVHCs in the chemicals or mixtures they supply. They may also ask for information that will help them submit an application for authorisation. SVHCs in imported articles do not need to be authorised. As with registration, an OR can make an application for authorisation; this takes the responsibility away from the EU importer.

Actions checklist

To work effectively with REACH, companies should:

  1. Identify exported substances: list all chemical substances you are exporting to the EU and check if they are subject to registration, authorisation, or restriction under EU REACH. Your EU customers may want to know which chemical substances they will need to register or apply for authorisation for. EU customers will not be able to import any products that contain restricted chemicals.
  2. Liaise with your EU customers: especially if they are a new customer or you are supplying a new product to an existing customer. They may already have registered the chemicals you are supplying or they may need to make a new registration.
  3. Consider appointing an EU-based Only Representative: to manage EU REACH obligations on the behalf of businesses based in Great Britain, including registration and authorisation where appropriate.
  4. Recordkeeping: ensure records are kept on quantities exported, safety data, and correspondence with your customers.

EU REACH in Northern Ireland

Please refer to online guidanceopens www.daera-ni.gov.uk in a new tab from the Northern Ireland Department of Agriculture, Environment and Rural Affairs.

Useful Links

General Overview

Guidance Documents

Registration Process

GB companies may work with an EU-based Only Representative to register with the ECHA.

Compliance & Evaluation

Support for Non-EU Companies

Tailored support for established exporters

Depending on your circumstances, DBT may be able to provide more tailored one-to-one support for your business.

We're interested in hearing from UK businesses who have an export plan and are operationally ready to do business internationally or established already

Our export support team can explain further support options for your business.

Follow us

Last updated: