PRODUCT STEWARDSHIP
Scientific rigour. Practical assurance.
Menu
EXPERTISE · MANUFACTURERS & IMPORTERS
REACH Basics for Manufacturers and Importers
The path from first manufacturing or importing a substance through to an active, maintained registration, in Great Britain and the EU.
If you manufacture or import a substance, this is where REACH starts.
Manufacturers and importers carry the primary duty under REACH: if you make a substance in, or bring it into, Great Britain or the EU above one tonne a year, the responsibility for registering it sits with you, not further down the supply chain. That responsibility runs from first establishing whether you are in scope through to keeping an active registration current for as long as you continue to supply the substance.
The process below sets out the eight stages that duty typically moves through, whether you are registering with ECHA for the EU market, with HSE for Great Britain, or both.
✓Scoping whether registration applies to your substance and tonnage
✓Article 26 inquiry and data-sharing support
✓Dossier preparation and joint submission coordination
✓Ongoing registration review and maintenance
THE EIGHT-STAGE PROCESS
From first scoping to an actively maintained registration.
The stages run broadly in this order, though registration review, authorisation and restriction are ongoing concerns that continue for as long as you supply the substance, not one-off steps you complete and move past.
1
Establish whether you need to register
Work out whether your substance falls within REACH’s scope, and whether the tonnage you manufacture or import crosses the one-tonne-a-year threshold. This is also the point to check for an exemption, or whether an Only Representative is already registering on a non-UK or non-EU manufacturer’s behalf.
2
Submit an inquiry before you register
Before registering, you are required to submit an inquiry (Article 26) to the relevant authority — ECHA for the EU market, HSE for Great Britain — to find out whether the substance has already been registered. The inquiry puts you in contact with existing and other potential registrants of the same substance.
3
Share data with other registrants
Where the substance already has registrants, REACH expects data to be shared rather than duplicated, particularly for animal testing. That usually means agreeing data and cost sharing with the lead registrant and joining their joint submission, often through a Letter of Access.
4
Prepare your registration dossier
Build the technical dossier your tonnage band requires, reflecting your own production quantities and the uses your customers actually put the substance to. Data requirements increase considerably as tonnage rises, and the dossier is prepared in IUCLID format.
5
Submit your registration
Registrations are normally submitted as part of the agreed joint submission; an individual submission is possible but attracts a higher fee and needs justifying. The submission is checked for completeness before you can lawfully continue to manufacture or import.
6
Keep your registration under review
A registration is not a one-off filing. It needs to stay current as tonnage, uses or classification change, and a registered substance can still be selected for closer evaluation by the authorities at any point.
7
Watch for authorisation requirements
If your substance is added to the Authorisation List, continued use after its sunset date needs a specific authorisation, granted only where risk is adequately controlled or the benefits are judged to outweigh it.
8
Watch for restrictions
Separately from authorisation, a substance can be restricted at any point, limiting or banning specific uses regardless of its SVHC status — and restrictions can apply to substances, mixtures and articles alike.
GB & EU: TWO SEPARATE JOURNEYS
The same eight stages, run twice, for two markets.
If you manufacture or import into both Great Britain and the EU, completing this process for one market does not carry any standing in the other. See our REACH Registration page for how ECHA and HSE deadlines and fees currently compare.
Registering with ECHA
Runs the same eight-stage shape for the EU market: Article 26 inquiry, data sharing, dossier preparation in IUCLID, submission through REACH-IT, and ongoing review, authorisation and restriction exposure once registered.
Registering with HSE
Runs the equivalent process independently for the GB market, retaining the same “one substance, one registration” principle and inquiry step, but as a legally separate registration from anything held with ECHA.
HOW WE HELP
Support at every stage, not just the paperwork.
Most of the risk in this process sits at the start and the end: getting the initial scoping wrong, or letting a registration go stale once it is in place.
We help manufacturers and importers work through each of the eight stages, coordinate with lead registrants and consortia, and keep a registration current as tonnage, uses, classification, authorisation and restriction positions continue to move.
✓Scoping and tonnage assessment for new and existing substances
✓Article 26 inquiry, data sharing and consortium support
✓Dossier preparation and joint submission coordination
✓Ongoing registration review as tonnage, uses and classification change
Ready to talk through your requirement?
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