There isn’t a new UK REACH announcement worth repeating today, but there’s an important wider compliance direction worth putting on the radar. ECHA’s 2026–27 enforcement programme specifically prioritises imports, following earlier enforcement findings that included 16% non-compliance among imported products checked against REACH restrictions. Online sales and checks spanning several pieces of chemicals legislation are also priorities. ECHA has been clear that these figures came from risk-based inspections targeting higher-risk consignments, not a representative sample of the entire market, so the real non-compliance rate across all imports is likely lower. Even accounting for that, a 16% failure rate among the shipments enforcement chose to check is not a small number.
Why this matters particularly for defence importers
Defence supply chains often source components from outside Europe through multiple tiers of suppliers, and historically, a lot of that assurance has rested on a single mechanism: a supplier declaration stating the component is compliant. When enforcement attention is broad and evenly spread, that’s a manageable risk. When enforcement is specifically prioritising imports, it stops being a background risk and becomes the exact profile enforcement is looking for.
Why supplier declarations alone are a weak assurance model
A declaration is a claim, not evidence. It tells you what a supplier says is true, not what’s been independently checked. That’s been an acceptable gap to carry when enforcement resources were spread thinly and imports weren’t a specific focus. It’s a much less comfortable gap to carry now that ECHA has said, in effect, that imported articles are where it’s looking.
A stronger model: declaration, BOM data, evidence, verification
- Declaration. Still the starting point, but treated as a claim to be checked rather than a conclusion in itself.
- BOM data. Cross-referencing the declaration against actual bill-of-materials composition, rather than accepting a general statement at face value.
- Evidence. Test certificates, analytical data or other substance-level documentation that backs the declaration up with something concrete.
- Verification. An independent check, whether that’s periodic auditing, spot-testing or third-party review, rather than relying on trust alone.
None of these four layers are new ideas individually. What’s changed is the case for treating them as a connected system rather than optional extras, particularly for imported articles that fit the profile enforcement is actively checking.
What to do now
- Identify which of your imported components carry the highest risk profile: non-EU origin, multiple supply chain tiers, or limited existing documentation.
- Prioritise those components for the fuller declaration-plus-evidence-plus-verification model, rather than trying to apply it everywhere at once.
- Review whether any products move through online sales channels, given ECHA has flagged that as a parallel enforcement priority alongside imports.
- Build verification into your ongoing supplier relationships now, rather than reacting if an import is ever stopped or queried.
How we can help
We help clients build material assurance for imported articles that goes beyond a supplier declaration, combining BOM verification, evidence gathering and independent checks, particularly for defence supply chains sourcing from outside Europe. Get in touch if you’d like us to review your current import assurance process against this stronger model.
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