“Don’t worry, we’re REACH compliant.” “This product is RoHS compliant.” It’s one of the most common lines a business development manager or sales rep will offer when a compliance question comes up in a conversation — usually said with total confidence, and usually with nothing behind it. It’s worth being genuinely wary of that sentence on its own, because on its own, it’s not evidence of anything.
A verbal assurance isn’t a compliance position
A sales rep telling you a product is compliant costs them nothing to say and is rarely something they’ve personally verified. It may well be true. It may also be optimistic, outdated, or simply what every rep at that company has been told to say regardless of the product. Either way, a spoken or emailed reassurance with no substance-level detail behind it isn’t something you can point to later if a customer, auditor or regulator asks how you know.
What “compliant” should actually come with
A genuine compliance position is backed by something specific, not a general statement. That means:
- A current safety data sheet, consistent with the product actually being supplied.
- Substance-level declarations — which substances, at what concentration, checked against which version of the relevant list.
- Test certificates or analytical data where restriction limits apply, not just a claim that limits are met.
- A named, traceable source for the information, not just “our supplier told us.”
If a supplier can’t produce any of that on request, “we’re compliant” is an opinion, not a position.
Ask for evidence, every time
The habit worth building is simple: when a supplier or their sales contact asserts compliance, ask for the evidence behind it, in writing, and keep it on file. Not as a one-off due diligence exercise when a new supplier is onboarded, but as a standing practice whenever a claim is made — particularly for products or components changing specification, formulation or origin.
Accidental compliance is not compliance
A business that happens to be fine, but never actually checked, hasn’t achieved compliance — it’s got lucky. Without the underlying data, without a record of having asked and received evidence, there’s no way to demonstrate that position if it’s ever challenged, and no way to know when it stops being true as formulations or supply chains change. Not checking, not holding the data, and not having it on file is, at best, accidental compliance — and accidental positions don’t hold up under scrutiny.
How we can help
We help clients build the habit of asking for, and properly recording, the evidence behind supplier compliance claims — so “we’re REACH compliant” becomes a documented, defensible position rather than something taken on trust.
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