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EXPERTISE · EU REACH

EU REACH

The EU’s framework for the registration, evaluation, authorisation and restriction of chemicals.

The four pillars of REACH.

REACH takes its name from its four core mechanisms: Registration, Evaluation, Authorisation and Restriction. Together they form a single system for managing the risks that chemical substances can pose, from the point a substance is first placed on the market through to how its riskiest uses are controlled or phased out.
Registration
Manufacturers and importers must register substances they place on the EU market above one tonne per year, submitting a technical dossier of hazard, use and exposure information to the European Chemicals Agency (ECHA). We help organisations work out which of their substances actually need registration, at what tonnage band, and what a proportionate dossier looks like.
Evaluation
ECHA and Member State authorities review registration dossiers and, where a substance raises a specific concern, examine it in more depth to decide whether further information or risk management is needed. We help organisations respond to evaluation requests and decide what additional data or justification is genuinely required.
Authorisation
Substances of very high concern can be placed on the Candidate List and, ultimately, the Authorisation List, after which their use requires specific authorisation unless an exemption applies. We help organisations identify authorisation-listed substances in their supply chain, assess exposure routes, and plan substitution or authorisation applications in good time.
Restriction
Where a substance poses an unacceptable risk in particular uses, REACH can restrict or ban that use EU-wide, regardless of registration or authorisation status. We help organisations track relevant restriction proposals, understand scope and transition periods, and plan reformulation or supply chain changes ahead of deadlines.
THE HISTORY OF REACH

From a 2001 policy paper to Europe’s core chemicals law.

REACH has its roots in a European Commission white paper published in 2001, which made the case for replacing a patchwork of around 40 separate pieces of EU chemicals legislation with a single, more coherent framework. That process led to Regulation (EC) No 1907/2006, adopted in December 2006 and entering into force on 1 June 2007, which established the European Chemicals Agency (ECHA) in Helsinki to administer it.

Rather than applying all at once, REACH’s registration duties were phased in through staged deadlines running from 2010 to 2018, based on tonnage and hazard profile, giving industry time to build the data and dossiers the regulation depends on. Nearly two decades on, this is still the framework EU REACH obligations are measured against today.

HOW WE HELP

From four pillars to demonstrable compliance.

Understanding Registration, Evaluation, Authorisation and Restriction is only the starting point. Turning that understanding into a position you can defend under scrutiny means working across all four pillars together, on an ongoing basis, rather than treating each as a one-off exercise. Getting any of this wrong carries real consequences — see our page on the risks of non-compliance for what is actually at stake.
✓Portfolio-wide substance and tonnage mapping, kept current as products, formulations and suppliers change
✓Registration and evaluation support, from dossier scoping through to responding to ECHA or Member State queries
✓Authorisation and substitution planning for Candidate List and Authorisation List substances in your supply chain
✓Restriction horizon-scanning, so reformulation and transition work starts well ahead of confirmed deadlines
✓Audit-ready decision records that show the reasoning behind a compliance position, not just the outcome
IDENTIFY YOUR PRODUCT

What type of product are you dealing with?

REACH treats different physical forms of a product differently, and the obligations that follow depend on getting this right first. We help you establish exactly what you have, for every substance and article in your range.

Substance
A chemical element or compound in its natural state or resulting from a manufacturing process, on its own or with any additives needed to keep it stable.
Mixture
A mixture or solution composed of two or more substances, such as a paint, cleaning product, adhesive or lubricant.
Article
An object given a specific shape, surface or design during manufacture that determines its function more than its chemical composition does, such as a component, fastener or textile.
Container
Packaging or housing that holds a substance or mixture without itself being the product, though its own material can raise separate compliance questions.
Article with intended release
An article specifically designed to release a substance during normal use, such as a scented product or a slow-release coating, which brings its own registration duties.
Material assurance
IDENTIFY YOUR ROLE

What is your role for this substance or article?

The same substance can sit under different obligations depending on where you sit in the supply chain, and that role is rarely the same across an entire product range. We help establish your role for each substance and article individually.

Manufacturer
You produce the substance, whether for your own use or to place on the market, and carry the primary registration duty.
Importer
You bring the substance, mixture or article into the UK or EU market from outside, taking on registration or notification duties as if you were the manufacturer.
Downstream user
You use a substance or mixture in your own industrial or professional activity, relying on the safety information and authorisations obtained further up the supply chain.
Distributor
You place a substance or mixture on the market for a third party without altering it, with duties focused on passing on safety information accurately.
Consumer
You use a product without any further supply chain duty, though you retain rights such as requesting SVHC information under Article 33.
Team discussing compliance roles

From classification to a working action plan.

Knowing your product type and your role is only useful once it is turned into a specific list of obligations — what needs to be registered, notified, communicated or authorised, and by when.

We help translate that into a practical action plan: who owns each obligation, what evidence is needed, and how the plan gets reviewed and kept current as products, roles and regulation all continue to change.

✓Mapping each substance and article against its correct product type and your role for it
✓Identifying the specific obligations that follow from that combination
✓Building an action plan with clear ownership, evidence requirements and deadlines
✓Reviewing and maintaining the plan as products, suppliers and regulation change

Specific provisions we are asked about often

Some obligations under REACH sit within specific articles that businesses ask about often. We have set out three of the most common below.

These provisions most often turn on whether a substance is a Candidate List SVHC. See our guides to Substances of Very High Concern and PFAS, or our guides to REACH Registration and REACH Restrictions for the processes themselves.

SCIP DATABASE

Notifying SVHCs in articles to the SCIP database.

Alongside the Article 33 duty to communicate SVHC information down the supply chain, suppliers of articles containing a Candidate List substance above 0.1% by weight have a separate obligation: notifying that information to ECHA’s SCIP database (Substances of Concern In Products). The requirement applies to EU-based suppliers, importers and distributors of articles, and has been in force since January 2021.

SCIP dossiers use ECHA’s IUCLID format, and getting a notification right depends on the same groundwork as the wider Article 33 position: knowing which articles contain a Candidate List substance, at what concentration, and being able to evidence it.

✓Screening articles and bills of materials for SVHCs above the 0.1% SCIP threshold
✓Preparing article dossiers in IUCLID format
✓SCIP notification and ongoing dossier maintenance
✓Aligning SCIP positions with wider Article 33 and REACH obligations
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