PRODUCT STEWARDSHIP
Scientific rigour. Practical assurance.
Menu
FREQUENTLY ASKED QUESTIONS
REACH FAQs
Straight answers to the questions we are asked most often about UK and EU REACH, and where to go on this site for the detail behind each one.
A large regulation, organised into a few manageable layers.
REACH reads as intimidating mostly because of its size, not its structure. The legal text is organised into Titles covering registration, evaluation, authorisation and restriction, plus a further set of Titles dealing with ECHA’s administration, data confidentiality and enforcement. Each Title breaks down into Articles that set the actual legal obligations, and a set of Annexes that supply the technical detail behind them — data requirements, restricted substance entries, exemption lists and more. Guidance documents from ECHA and HSE then sit on top of all of it, interpreting how the Articles and Annexes apply in practice.
The questions below cover the ones we are asked most often, with links through to the pages on this site that go into more depth on each topic.
REACH BASICS
Understanding the essentials.
What is REACH actually trying to achieve?
REACH exists to protect human health and the environment from the risks chemicals can pose, while still allowing substances to move through the market and supply chains freely once those risks are properly understood and managed. The trade-off it strikes is between safety and the practical needs of industry, not one at the expense of the other.
In outline, how does REACH actually work?
If you manufacture or import a substance above one tonne a year, you register it with the relevant authority (ECHA for the EU market, HSE for Great Britain), submitting a dossier of data on its properties and safe use. The authority checks the dossier is complete, may evaluate a proportion of dossiers or testing proposals in more depth, and can select substances of concern for closer substance evaluation. Substances that raise particular concern can be added to the Candidate List of substances of very high concern (SVHCs), which is the route into authorisation and, separately, restriction — the two main tools REACH uses to control substances that raise serious concern. See our REACH Registration page for how the dossier itself is put together.
Who does REACH actually apply to?
REACH applies directly to manufacturers, importers, distributors and downstream users established in the market in question — the EU/EEA for EU REACH, or Great Britain for UK REACH. A manufacturer outside that market can appoint an Only Representative to handle registration on its behalf; where that happens, its customers are treated as downstream users rather than importers. Where it does not happen, the registration duty defaults to whoever is doing the importing — see our note on the importer pitfall for how often this gets missed.
What is the difference between a substance, a mixture and an article?
A substance is a chemical element or compound in its own right. A mixture is two or more substances combined, such as a paint or a lubricant. An article is an object given a specific shape, surface or design that determines its function more than its chemical composition does — a fastener or a cable, for example. REACH treats each differently, which is why the same underlying substance can trigger different duties depending on the form it is supplied in.
SCOPE & EXEMPTIONS
What is covered, and what sits outside REACH.
Which substances are exempt from REACH?
A short list sits entirely outside REACH’s scope, including radioactive substances, substances under customs supervision without being processed, non-isolated intermediates, substances in transport, and waste. Beyond that, certain uses are carved out from specific parts of REACH — substances in medicines and food, for example, are excluded from registration under Title II, and Annexes IV and V list further substances excluded because the risk is considered low or registration would be disproportionate.
Is there a defence exemption from REACH?
Under Article 2(3), individual states, including the UK for UK REACH, can exempt specific substances, mixtures or articles from REACH where necessary in the interests of defence. It is not automatic: it typically needs a specific application to the relevant national authority, and the scope of what is covered is decided case by case. We can help work through whether a defence exemption is realistic for a given material and how to evidence the case for it.
Are nanomaterials covered by REACH?
Yes. Since 2020, nanoforms of a substance carry their own specific registration requirements, added to REACH’s Annexes to address the particular properties and risks nanomaterials present, on top of the standard registration duties that already apply above the one tonne threshold.
SVHCs, AUTHORISATION & RESTRICTION
The two routes REACH uses to control substances of concern.
What are SVHCs, in plain terms?
Substances of Very High Concern are substances identified as carrying particularly serious and often irreversible hazards — carcinogens, mutagens and reproductive toxins, persistent and bioaccumulative substances, or substances raising an equivalent level of concern such as endocrine disruptors. See our full guide to Substances of Very High Concern for the detail.
What is the Candidate List, and how is it different from the Authorisation List?
The Candidate List is where a substance lands once it is formally identified as an SVHC, and that listing alone triggers communication and SCIP notification duties for articles above 0.1% by weight. The Authorisation List (Annex XIV) is a smaller, prioritised subset of the Candidate List: once added, a substance is given a sunset date after which it cannot be used without a specific authorisation. Our SVHC page sets out the distinction in full, since the two are very often confused.
What does it mean if a substance sits on the restrictions list?
A restriction limits or bans the manufacture, sale or use of a substance where the risk it presents is not being adequately managed any other way. Unlike authorisation, a substance does not need to be an SVHC to be restricted, and most restriction entries carry specific conditions or concentration limits rather than an outright ban. Our REACH Restrictions page covers how the process works and how to interpret an entry against a real product.
ARTICLES, REGISTRATION & COSTS
Practical questions on obligations and cost.
I manufacture, import or supply finished products — what are my obligations?
It depends on what the product contains and how it is used. If a substance is intended to be released from the article in normal use, or if the article contains an SVHC above 0.1% by weight, registration or notification duties under Article 7 can apply once total tonnage passes one tonne a year. Suppliers of articles containing an SVHC above that threshold also carry an Article 33 communication duty, and often a SCIP notification obligation. See our pages on Article 7, Article 33 and Article 66 for each duty in detail.
How much does REACH registration actually cost?
There is no single figure: cost depends on your tonnage band, company size, whether you are joining an existing consortium or building a dossier from scratch, and the fee schedule of whichever regime you are registering into. Our REACH Registration page breaks down what goes into a dossier, current deadlines, and how ECHA and HSE fees differ.
How does UK REACH differ from EU REACH?
They have been legally separate regimes since the end of the EU Exit transition period. Registering with ECHA gives you no standing under UK REACH, and vice versa; the two run their own Candidate Lists, restriction lists and deadlines, which can diverge even where the underlying substance and risk are identical. See our dedicated UK REACH and EU REACH pages for how each regime is currently run.
How does REACH differ from RoHS?
REACH covers chemical substances generally, across mixtures and articles, wherever they are used. RoHS is narrower in scope but more absolute in effect: it restricts a fixed list of ten hazardous substances specifically within electrical and electronic equipment, largely on hazard grounds rather than the detailed risk-and-alternatives assessment REACH restrictions go through. A product can sit inside both regimes at once. See our RoHS page for the detail.
Question not covered here?
Tell us where the uncertainty sits. We will help you define the requirement and the right level of support.
Product Stewardship
Need help with REACH, CLP or material compliance?
Get specialist regulatory and material assurance support across the UK, EU, industry and defence sectors — REACH, CLP, BPR, DSEAR and the evidence to back it up.
ProductStewardshipProduct Stewardship Ltd provides specialist regulatory support, material assurance and compliance training for organisations operating across the UK, EU, industry and defence sectors.
Coverage: UK, EU & Defence sectors
Regulators: HSE & ECHA
Services
Contact & Help
Speak to us about REACH, CLP, defence material assurance, training or workplace compliance.
© 2026 Product Stewardship Ltd
Product Stewardship Ltd · Registered in England & Wales, Company No. 12143264 · Registered office: 140 Lee Lane, Horwich, BL6 7AF · VAT No. GB430 9538 93