REACH Compliance Updates: What Chemical Importers and Exporters Need to Know
REACH Compliance Updates: What Chemical Importers and Exporters Need to Know
The European Union's REACH Regulation remains one of the most important regulatory frameworks affecting international chemical trade. For chemical manufacturers, importers, exporters and distributors, compliance involves more than registering substances. Businesses must also manage chemical safety information, communicate hazards, monitor restricted substances and maintain accurate supply chain documentation.
As regulatory requirements and substance restrictions continue to evolve, companies supplying the European Economic Area (EEA) need to review their compliance procedures regularly. Understanding registration obligations, updated substance lists and importer responsibilities is essential for maintaining market access and avoiding costly supply chain disruptions.
Understanding the REACH Regulation
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is governed by Regulation (EC) No 1907/2006 and applies across the EU and EEA countries: Iceland, Liechtenstein and Norway.
The regulation aims to protect human health and the environment by requiring companies to identify and manage chemical risks. It also encourages the substitution of particularly hazardous substances with safer alternatives where technically and economically feasible.
The main components of REACH include:
Registration: Submission of relevant substance information to the European Chemicals Agency (ECHA).
Evaluation: Assessment of registration dossiers and chemical safety information.
Authorisation: Control of certain substances of very high concern (SVHCs).
Restriction: Limitation or prohibition of substances presenting unacceptable risks.
For businesses involved in international chemical trade, these requirements influence product approvals, sourcing decisions, documentation and market access.
Important REACH Compliance Updates to Monitor in 2026 and 2027
1. REACH Regulation Revision and Regulatory Simplification
The European Commission is reviewing the REACH framework to improve its effectiveness and adapt it to scientific and regulatory developments.
The Commission's work includes assessing possible changes to registration requirements, chemical safety information, risk management and regulatory procedures.
The European Chemicals Agency's 2026 report on REACH and CLP implementation also highlights a shift towards more systematic screening and prioritisation of substances already included in regulatory databases.
For chemical importers and exporters, this means compliance should not be limited to checking whether a substance has an existing registration. Businesses should also monitor changes to hazard information, substance evaluations and regulatory restrictions.
Companies should distinguish between proposals, ongoing reviews and adopted legal requirements. A proposed revision does not automatically create a new compliance obligation.
2. Candidate List of Substances of Very High Concern
The REACH Candidate List identifies substances that may eventually become subject to authorisation requirements. Inclusion can also trigger immediate communication and information obligations.
ECHA updated the Candidate List on 4 February 2026, bringing its total to 253 entries. The next update is currently anticipated in June 2027.
The 2026 update included n-hexane and several substances associated with serious health concerns, including reproductive toxicity.
Businesses should regularly review the Candidate List to determine whether listed substances are present in their products, mixtures or articles.
Key responsibilities include:
Identifying Candidate List substances in products and materials.
Updating relevant safety data sheets when required.
Providing customers with information for safe use.
Reviewing supplier declarations and product composition.
Assessing whether article notification obligations apply.
For articles containing an SVHC above 0.1% weight by weight, suppliers generally have to provide sufficient information for safe use to professional customers. Consumers who request this information must receive a response within 45 days.
Article producers and importers may also need to notify ECHA when the applicable conditions are met, including the relevant annual quantity threshold of more than one tonne per producer or importer.
3. Changes to the REACH Restrictions Roadmap
The European Commission published an updated REACH Restrictions Roadmap on 31 August 2026. It provides information about existing restrictions and substance groups under regulatory consideration.
Areas being examined include:
Per- and polyfluoroalkyl substances (PFAS).
Certain chromium (VI) compounds.
Bisphenols with endocrine-disrupting properties.
Certain brominated flame retardants.
Selected phthalates and organophosphorus flame retardants.
6PPD and related substances.
These developments are important for manufacturers using specialty chemicals, polymers, coatings, rubber additives and industrial processing materials.
However, the Restrictions Roadmap is not itself legally binding. Companies should distinguish between substances under investigation, proposed restrictions and restrictions formally adopted under REACH or other applicable legislation.
Businesses can use the roadmap as an early-warning tool to review product formulations, identify potential alternatives and discuss regulatory risks with suppliers.
4. Greater Attention to Imported Chemicals and Supply Chain Compliance
Imported substances and articles remain an important area of regulatory enforcement.
A 2026 EU Council document highlighted findings from ECHA's REF-12 enforcement project, which involved 2,603 inspections across 29 EEA countries. The reported findings included registration deficiencies in one out of three inspected substances in imported mixtures and non-compliance involving 16% of the restricted substances checked.
These findings underline the importance of checking the regulatory status of imported products rather than relying exclusively on supplier assurances.
Importers should verify:
Whether applicable substances are registered.
Whether annual import volumes have been calculated correctly.
Whether restrictions or authorisation requirements apply.
Whether safety data sheets are complete and current.
Whether product composition matches the supplied documentation.
For exporters outside the EEA, providing accurate chemical identity, composition and use information is essential to helping European customers fulfil their obligations.
REACH Responsibilities for Chemical Importers and Exporters
One of the most important aspects of REACH compliance is understanding which business entity is legally responsible for meeting each obligation.
Responsibilities of EU and EEA Importers
Under REACH, EU and EEA importers generally have responsibility for applicable registration obligations when importing substances from outside the region.
For substances imported on their own or in mixtures, the one-tonne-per-year registration threshold applies to each substance and legal entity, subject to relevant exemptions.
For mixtures, importers must consider the quantity of each individual substance across all relevant imports, not simply the total weight of the mixture.
Their responsibilities may include:
Identifying all chemical substances in imported products.
Calculating annual quantities for each substance.
Checking whether registrations cover the intended substance and relevant uses.
Submitting registration dossiers where required.
Ensuring applicable classification, labelling and packaging requirements are met.
Maintaining relevant safety and compliance documentation.
Registration must be completed before importing a substance when registration is required.
Responsibilities of Non-EU Chemical Exporters
Companies outside the EU and EEA are not directly subject to REACH as non-EU legal entities in the same way as EU-based importers. However, their products may still need to meet REACH requirements before entering the European market.
Non-EU manufacturers should support their European customers by providing:
Accurate substance identity and CAS or EC numbers.
Chemical composition and concentration details.
Annual volume and intended-use information.
Safety data sheets and hazard classification data.
Information about Candidate List substances.
Relevant testing and technical documentation.
A non-EU manufacturer may appoint an EU-based Only Representative (OR) to fulfil the REACH obligations that would otherwise apply to its EU importers, where the legal conditions are met.
This arrangement can simplify compliance for multiple EU customers, but it requires appropriate documentation and coordination of covered substances, volumes and importers.
REACH Registration Requirements and Exemptions
Registration is one of the central obligations under REACH. It generally applies to substances manufactured or imported in quantities of one tonne or more per year per legal entity, unless an exemption applies.
The registration process involves gathering information about the chemical's identity, properties, hazards, uses and safe handling requirements.
Information Required for Registration
Depending on the substance and tonnage band, registration dossiers may require:
Substance identification and composition.
Physicochemical properties.
Toxicological information.
Ecotoxicological information.
Identified uses and exposure information.
Risk management measures.
Chemical Safety Assessment and Chemical Safety Report, where required.
The amount of information required generally increases with the applicable tonnage band.
Understanding Registration Exemptions
Not every chemical substance requires registration. REACH contains exemptions for certain substances, uses and activities.
Examples include specified exemptions for certain naturally occurring substances, certain substances used in food and medicinal products, and substances covered by other regulatory provisions.
Polymers are generally exempt from registration under REACH, although their monomers and other relevant substances may have registration obligations.
Companies should not assume that a substance is exempt simply because it is widely used or has been purchased from another supplier. Each exemption must be assessed against the applicable legal conditions.
Safety Data Sheets and Chemical Labelling Requirements
Safety data sheets (SDSs) are essential documents for communicating chemical hazards and safe handling information throughout the supply chain.
Under REACH, SDS requirements are established in Article 31 and Annex II. The EU format was updated through Regulation (EU) 2020/878.
An SDS generally contains 16 sections covering:
Chemical identification and supplier information.
Hazard identification.
Composition and ingredient information.
First-aid and firefighting measures.
Accidental release and handling precautions.
Exposure controls and personal protection.
Physical and chemical properties.
Stability and reactivity.
Toxicological and ecological information.
Disposal, transport and regulatory information.
Manufacturers and importers must ensure that SDSs are accurate, updated when legally required and supplied in the appropriate language for the relevant market.
Chemical labels must also comply with the EU CLP Regulation, including applicable hazard pictograms, signal words, hazard statements and precautionary statements.
Authorisation and Restriction: Understanding the Difference
REACH authorisation and restriction are separate regulatory mechanisms, and chemical businesses should understand how each affects their products.
Authorisation Under Annex XIV
Authorisation applies to substances included in REACH Annex XIV. Companies generally cannot place these substances on the market or use them after their relevant sunset dates unless an applicable exemption or authorisation applies.
The process is designed to control the risks associated with SVHCs and encourage the use of safer alternatives.
Importers and manufacturers should check whether their substances are listed in Annex XIV and whether their intended uses are covered by an authorisation.
Restrictions Under Annex XVII
Restrictions control or prohibit the manufacture, placing on the market or use of particular substances under specified conditions.
Unlike authorisation, restrictions can apply to substances, mixtures and articles, depending on the relevant entry.
Businesses should review Annex XVII before introducing products into the EEA market, particularly when dealing with substances used in coatings, plastics, textiles, cleaning products and other regulated applications.
Practical REACH Compliance Checklist for Businesses
Chemical importers and exporters can improve regulatory readiness through a structured compliance process.
1. Review chemical inventories: Maintain an updated list of substances, mixtures, products and relevant composition details.
2. Verify registration status: Check registration requirements, annual volumes and the legal entity responsible for registration.
3. Monitor ECHA lists: Review the Candidate List, Authorisation List and Restriction List regularly.
4. Check supplier documentation: Obtain updated SDSs, certificates of analysis and chemical composition information.
5. Review product labels: Ensure classification, labelling and packaging comply with applicable EU requirements.
6. Assess article obligations: Identify SVHCs in imported articles and evaluate relevant communication and notification requirements.
7. Maintain records: Keep registration evidence, supplier declarations, import volumes and technical documentation accessible.
8. Monitor regulatory developments: Track adopted amendments, proposed restrictions and relevant ECHA announcements.
The Business Impact of REACH Compliance on International Chemical Trade
REACH compliance has a direct influence on the competitiveness of companies participating in international chemical supply chains.
For importers, inadequate documentation or missing registrations can lead to shipment delays, enforcement action and restrictions on market access. Exporters may also face commercial difficulties if their products cannot satisfy the regulatory requirements of European customers.
Effective compliance management can offer several business advantages:
More reliable access to the European chemical market.
Improved relationships with international buyers.
Reduced risk of regulatory interruptions.
Better visibility into product composition and supplier performance.
More informed decisions about alternative substances and formulations.
Greater confidence in product safety documentation.
For businesses operating across multiple jurisdictions, REACH should be integrated into wider regulatory management rather than handled as a separate administrative task.
Preparing for Future REACH Requirements
The REACH regulatory environment will continue to evolve as European authorities assess chemical hazards, review restrictions and improve the implementation of existing legislation.
The expected June 2027 Candidate List update and ongoing work on restrictions demonstrate why companies need to monitor substance-specific developments. Businesses should also pay attention to the European Commission's broader REACH review and changes to related chemical legislation.
Chemical importers and exporters that maintain accurate inventories, verify supplier information and regularly assess their products against ECHA requirements will be better positioned to manage regulatory risks.
Ultimately, REACH compliance is an ongoing responsibility. A proactive approach to chemical registration, hazard communication and supply chain transparency can help manufacturers and distributors protect market access while supporting safer chemical trade.
Sources
Ammonium Sulphate - Taiwan
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