Chemicals
REACH Compliance EU: Requirements for Products Sold in the EU
REACH compliance EU-wide is not a product-marking rule like CE or a fixed substance list like RoHS — it is a chemical-registration system with three genuinely separate duties (registration, authorisation, restriction), and most of it applies to substances and mixtures, not finished consumer products directly. REACH requirements for products reach a typical finished good through one narrower path — this page explains what that path actually is and what to check first.
What Most Sellers Actually Need to Check
- SVHC in articles: substances of very high concern above 0.1% by weight
- Who registers: manufacturer, importer, or an appointed Only Representative
- SCIP notification: a separate database duty for articles containing SVHCs
- Not the same as RoHS: broader substance scope, not limited to electronics
Quick answer: REACH compliance for products sold in the EU comes down to three genuinely separate duties under Regulation (EC) No 1907/2006 — registering substances above certain tonnage thresholds, seeking authorisation for specific high-concern uses, and respecting outright restrictions on certain substances. For most sellers of finished consumer products, the practical question is narrower: does the product contain a Substance of Very High Concern (SVHC) above 0.1% by weight in any article, which then triggers both a customer-notification duty and, since 2021, a SCIP database notification — not full substance registration, which applies further up the supply chain.
Why REACH Confuses Finished-Goods Sellers
REACH Was Built for Chemical Supply Chains, Not Finished Products
Most content answering "eu reach compliance" is written from the perspective of a chemical manufacturer or importer registering substances directly with ECHA — accurate for that audience, but largely irrelevant to a seller of finished consumer products who never handles a raw substance directly. That mismatch is the real source of confusion: a seller searching "REACH product compliance" is usually trying to find out whether REACH reaches their finished product at all, and if so, through which of the three duties — not trying to learn how to register a chemical substance they don't manufacture.
The practical answer for most finished-goods sellers is that registration and authorisation rarely apply directly — those sit with whoever manufactures or imports the substance itself, which for many products is a component supplier several tiers up the chain. What actually reaches a finished-goods seller most often is the restriction duty, specifically the SVHC/SCIP threshold covered below, which can apply regardless of where in the supply chain the substance was originally registered.
Three Duties, Not One
Registration, Authorisation, Restriction
"REACH compliance" as a single phrase hides three structurally different obligations — knowing which one actually applies to you matters more than a generic checklist.
Registration
Manufacturers and importers of substances above 1 tonne/year must register them with ECHA, providing safety data scaled to the tonnage band. This sits with whoever brings the substance itself into the EU — often further up the supply chain than a finished-product seller.
Authorisation
Substances on the Authorisation List (Annex XIV) cannot be used for certain purposes without specific ECHA authorisation, granted case by case — relevant mainly to manufacturers using specific high-concern substances in production, not typical finished-goods sellers.
Restriction
Substances on the Restriction List (Annex XVII) are banned or limited outright for certain uses — this is the duty most likely to reach a finished consumer product directly, since it can restrict a substance's presence in the product itself, not just in how it's manufactured.
Who Registers
Who Actually Carries the Registration Duty
EU-based manufacturers and importers
The default registrants — whoever manufactures a substance in the EU or imports it into the EU above the 1-tonne/year threshold carries the registration duty directly.
Only Representative (non-EU manufacturers)
A non-EU manufacturer can appoint an EU-based Only Representative to handle REACH registration on its behalf, keeping the compliance burden off the EU importer instead. Full guide, including cost and the OR-vs-AR-vs-RP confusion →
SVHC & SCIP
What Actually Reaches a Typical Finished Product
Full substance registration is rare for finished-goods sellers. This is the duty that actually applies to most of them.
The 0.1% SVHC threshold
If any article in your product contains a Candidate List SVHC above 0.1% weight by weight, you have a customer-information duty on request — and, since 2021, a mandatory SCIP database notification before placing the product on the market, regardless of whether a customer actually asks.
SCIP notification
SCIP (Substances of Concern In Products) is ECHA's dedicated database for exactly this scenario — a separate notification duty from REACH registration itself, and one that catches finished-product sellers who never register a substance directly. Full field-by-field guide →
REACH vs RoHS
Extending the Comparison From Our RoHS Guide
Our RoHS guide already compares the two at a glance — this is the deeper version.
| RoHS | REACH | |
|---|---|---|
| Substance scope | 10 named substances, fixed list | Thousands of substances via the Candidate List, Authorisation List and Restriction List — actively updated |
| Product scope | Electrical and electronic equipment only, 11 defined categories | Any product containing a regulated substance — not limited to electronics |
| Core mechanism | A restriction on presence above a fixed concentration | Three separate mechanisms — registration, authorisation, restriction — each with its own trigger |
| Where it typically bites a finished-goods seller | Substance testing evidence folded into the CE technical file | The SVHC/SCIP duty specifically, not full registration |
Real Scenario
A Pattern Worth Checking Your Own Supply Chain Against
The multi-component product with one unchecked part
A genuinely common pattern: a seller sources a finished product assembled from several components — a metal fastener, a plastic housing, a printed cable — each from a different supplier. The seller checks the main housing material against the SVHC list and finds it clean, and reasonably assumes the whole product is covered. What frequently gets missed is that each component is its own "article" under REACH, and the 0.1% SVHC threshold applies per article, not to the product's average composition — a small metal part with a plating process using a Candidate List substance can trigger the SCIP duty even while the bulk of the product by weight is unaffected. Checking only the dominant material by weight is the specific trap worth avoiding.
Evidence & Enforcement
What You Need on File, and What Happens If You Don't
Evidence to hold
Supplier declarations or test data confirming SVHC content is below 0.1% (or, where above, confirming the SCIP notification was filed) — the same evidence-on-request pattern already established for GPSR and CE marking.
Enforcement pattern
National REACH enforcement authorities and customs checks follow the same general pattern as other product regimes covered on this site — documentation checks first, with market-access consequences for products that can't produce the required evidence.
Cost
What REACH Compliance Actually Costs, by Duty
SVHC/SCIP check
The lowest-cost end for most finished-goods sellers — supplier declarations or targeted lab testing per component, plus the SCIP notification itself where triggered.
Only Representative appointment
A recurring service cost for non-EU manufacturers who need substance registration handled on their behalf, distinct from and usually smaller than the registration cost itself.
Full substance registration
The highest-cost end, scaling with tonnage band and whether the substance is already registered by another party — this cost sits with substance manufacturers and importers, rarely with a finished-goods seller directly.
The free Product Compliance Check flags which of these cost categories your specific product is actually exposed to before you budget for any of them — most finished-goods sellers are surprised to find they sit in the lowest-cost category rather than needing full substance registration at all.
FAQ
Common Questions About REACH Compliance
Is REACH compliance the same as RoHS compliance?
No — they are separate regulations with different substance lists, different product scopes and different mechanisms. RoHS restricts 10 named substances in electrical/electronic equipment specifically; REACH covers a much broader, actively-updated set of substances across any product type, through three separate duties (registration, authorisation, restriction).
Do I need to register substances with ECHA to sell a finished product in the EU?
Usually not directly — full REACH registration applies to manufacturers and importers of the substances themselves, above tonnage thresholds. Most finished-goods sellers instead face the narrower SVHC/SCIP notification duty if their product's articles contain a Candidate List substance above 0.1% by weight.
What is the REACH Only Representative, and do I need one?
It's an EU-established party a non-EU manufacturer can appoint to handle REACH registration duties directly, keeping that burden off the EU importer. Full role detail, including when it makes sense versus other economic-operator arrangements, is covered on our Economic Operators guide.
How much does REACH registration cost?
Cost scales heavily with tonnage band and whether the substance is already registered by another party (joint registration can share cost) — there is no single figure that applies across substances, and this cost sits with substance manufacturers/importers rather than typical finished-goods sellers, who more often face the much lower-cost SCIP notification duty instead.
What is SCIP, and is it the same as REACH registration?
No — SCIP (Substances of Concern In Products) is a separate ECHA database notification duty for articles containing SVHCs above 0.1% by weight, introduced in 2021. It exists alongside REACH registration but catches a different, much broader set of sellers, including many who never register a substance under REACH directly.
Does the 0.1% SVHC threshold apply to my whole product or each component?
Each article within the product is assessed separately, not the product's overall average composition — a small component made mostly of a Candidate List substance can trigger the duty even if it is a tiny fraction of the finished product's total weight. Checking only the dominant material is a common and genuinely risky shortcut.
How often does the SVHC Candidate List change?
ECHA updates it periodically, typically a few times a year as new substances are proposed and added — a supplier declaration or test result confirming "clean" status at one point in time can become outdated, which is why this page recommends checking ECHA's current list directly rather than relying on a static internal record indefinitely.
Is REACH compliance required even if my product already has CE marking?
Yes — CE marking and REACH are separate legal requirements that can both apply to the same product simultaneously. A CE-marked product still needs to satisfy REACH's SVHC/SCIP duty (and any applicable restriction) independently; CE marking does not substitute for or imply REACH compliance.
Who should I ask for REACH compliance evidence — my factory or my customs broker?
Your supplier or factory, not your customs broker — a customs broker handles the logistics of import, not the underlying substance evidence, which needs to originate from whoever actually manufactures the component or article. Request supplier declarations at the sourcing stage rather than discovering a gap at the point of customs clearance.
Where do I actually complete REACH registration EU-wide?
REACH registration EU-wide is submitted directly to ECHA (the European Chemicals Agency) — there is no separate per-country registration step, unlike EPR. This applies to substance manufacturers, importers and Only Representatives, not typically to finished-goods sellers facing only the narrower SVHC/SCIP duty.
How do I check REACH substances in articles I sell?
Check REACH substances in articles by requesting supplier declarations or lab test results for each distinct component against ECHA's current SVHC Candidate List — per article, not per product average, as the multi-component scenario above explains.
Related Guides
Where to Go Next
Where the Facts Come From
Sources for This Page
Regulation (EC) No 1907/2006 (Tier 1, EUR-Lex) is the legal basis for every duty on this page. The SVHC Candidate List, Authorisation List, Restriction List and SCIP database are all maintained directly by the European Chemicals Agency (ECHA) — check ECHA's own published lists directly for the current substance status, since these lists are actively updated on their own schedule and this page does not attempt to reproduce or freeze a snapshot of them.
Not sure which REACH duty applies to your product?
Run the free Product Compliance Check to see which requirement clusters, including REACH's SVHC/SCIP duty, actually reach your specific product.
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