Nearly 19,000 initial chemical registrations and over 45,000 dossier updates landed on ECHA's desk across five years, and the agency just published a full accounting of what happened next. The European Chemicals Agency released its fourth operation report on REACH and CLP in June 2026, covering the 2021 to 2025 period. For anyone trading chemicals into the EU, this report is a rare full picture of how the system is actually functioning.
A Shift From Registration to Active Screening
The earlier operation reports focused heavily on registration deadlines. This one marks a clear turn. ECHA now spends more of its effort systematically screening substances already sitting in its database, prioritizing which ones need closer attention and applying targeted risk management where problems surface.
That shift matters because it changes where compliance risk actually sits. A registration filed years ago is no longer the end of the story. Substances already on file can still get flagged, questioned or pulled into evaluation long after the initial paperwork cleared.
Registration Numbers Tell a Story of Steady Activity
Registration volume held remarkably steady across the reporting period. ECHA recorded roughly 3,800 initial registrations per year on average, alongside about 361 new substance registrations annually, a figure the report points to as a sign the EU remains an active hub for chemical innovation.
One trend worth flagging for traders specifically: importers and Only Representatives now account for 81 percent of registrations combined, while the share held directly by EU manufacturers continues to shrink. Manufacturers still lead on new substance registrations though, filing 45 percent of those cases themselves.
Evaluation Work Cleared a Major Backlog
ECHA completed screening across every high tonnage dossier in its database during this period, a genuinely significant milestone. Compliance checks alone covered more than 10,000 dossiers, resulting in 1,198 formal decisions demanding roughly 6,700 additional pieces of information from registrants.
Substance evaluation cases dropped to about 7 new cases per year on average, but the number of completed conclusions rose to roughly 24 per year, which the report frames as clearing out a long standing backlog. About half of these evaluations ended up requiring additional data, most often tied to persistence, bioaccumulation, toxicity, endocrine disruption or mutagenicity concerns.
The Candidate List Keeps Growing
Forty four new Substances of Very High Concern joined ECHA's Candidate List during this period, bringing the total to 253 substances. Most additions came from reproductive toxicity concerns or persistent, bioaccumulative properties.
The authorization side of the system saw its own pressure build. Roughly 230 authorization applications came in, and nearly 90 percent of them related to chromium six compounds. That concentration created a genuine backlog, driven partly by downstream users filing individual applications after a European Court of Justice ruling changed how those applications needed to be submitted.
For buyers and suppliers dealing in nickel, chromium or other metal compounds with a history of REACH scrutiny, this pattern is a useful reminder. Authorization related substances can face sudden procedural shifts that ripple through supply chains well beyond the original ruling.
Restrictions and the PFAS Workload
Fourteen restriction dossiers moved through the system during this period, eight submitted by member states and six drafted directly by ECHA. The agency's scientific committees completed eleven formal opinions on these dossiers.
One restriction stands out above the rest. The proposal covering per and polyfluoroalkyl substances, widely known as PFAS, generated the highest assessment workload ECHA has ever handled on a single restriction. Anyone trading chemicals with fluorinated chemistry in their supply chain should treat this as an ongoing situation rather than a settled matter.
CLP Activity and the Move to ECHA CHEM
On the classification side, 202 substances saw new or revised harmonized classifications added to CLP Annex VI during the reporting period, including 63 substances classified in the strictest carcinogenic, mutagenic or reproductive toxicity categories.
New hazard classes introduced in 2023 and 2024, covering endocrine disruptors and persistent, mobile or toxic properties, moved from concept into formal implementation during this window. The Classification and Labelling Inventory also migrated onto the newer ECHA CHEM platform in May 2025, expanding from roughly 170,000 to 360,000 substances and becoming one of the largest GHS classification databases anywhere in the world.
Enforcement Findings Buyers Should Not Ignore
ECHA's enforcement network ran ten coordinated projects across the five year period, carrying out more than 20,000 inspections and training over a thousand inspectors across member states.
The compliance results from those inspections carry a warning for importers specifically. Thirty two percent of imported mixtures checked during enforcement work failed to meet basic registration obligations. Safety data sheets, online chemical sales and imported finished products all showed elevated non compliance rates as well.
This finding alone should push any company importing formulated products or mixtures into the EU to double check registration status before shipments move, rather than assuming a supplier's paperwork is automatically in order.
What Buyers Should Do Now
A report this dense rewards a practical response rather than a passive read. A few steps stand out for procurement teams sourcing into or within the EU market:
Audit dossier completeness and data timeliness for chemicals already registered in your supply chain, since evaluation activity is ongoing rather than one time.
Watch chromium and nickel related authorization filings closely given the current backlog and procedural shifts.
Track PFAS restriction developments actively, given the scale of regulatory attention this category is receiving.
Confirm safety data sheet accuracy on imported mixtures, given the elevated non compliance rate enforcement inspections uncovered.
The Bottom Line for Procurement Teams
ECHA's own conclusion is that REACH and CLP have matured into a more streamlined and predictable framework over the past five years, even as data quality, committee workload and enforcement coordination remain genuine challenges. For chemical traders, the practical takeaway is straightforward. Registration is only the starting point, not the finish line, and staying compliant now means treating dossier accuracy and supply chain documentation as an ongoing responsibility rather than a box checked once.
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Reference Link:
https://echa.europa.eu/-/echa-report-shows-continued-progress-in-implementing-reach-and-clp