REACH Restrictions
Where the risk from a substance is not adequately controlled any other way.
Four stages, usually over several years.
Restrictions do not appear without warning. The process is long and public, which gives organisations time to prepare, provided the proposal is being tracked in the first place.
Almost identical content, but not the same list.
ECHA and HSE each maintain their own restriction list, and while the entries overlap heavily in practice, they are legally separate documents, updated on separate timetables, by separate decision-makers.
The UK government has recently signalled it will prioritise alignment with EU chemicals regulation under UK REACH unless exceptional circumstances justify diverging, which should narrow the gap between the two lists over time — but narrowing is not the same as identical, and a position built against one list still needs to be checked against the other.
The entry’s wording rarely maps directly onto your product.
Very few restriction entries are a simple ban. Most set out specific conditions: a concentration limit below which the restriction does not bite, an exempted use, a particular product category the restriction applies to, or requirements that only apply above a certain scale of use.
Interpreting that correctly against your own product, formulation or process is where most restriction questions actually sit, and it is not always as literal as the entry’s wording first suggests — the restriction’s exact scope, the substance form it applies to, and how a mixture or article is treated can all shift the answer.
“It doesn’t apply to us” needs its own paper trail.
Concluding that a restriction does not apply to you is a decision, not an absence of one, and it needs to be recorded as carefully as a decision that it does apply. If a regulator, customer or auditor asks why a restricted substance appears in your product without a restriction being triggered, “we checked and it was fine” is not an answer that holds up.
A defensible out-of-scope position sets out which entry was considered, what data or reasoning supports the conclusion, and when it was reviewed — so the same question does not need to be re-answered from scratch if it is raised again months or years later.
Turning a restriction entry into a clear, evidenced position.
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