Eu Reach Compliance Services
EU REACH compliance services should produce an evidence-backed release decision, not a generic certificate. The work starts by identifying the product and legal entity, then routes substances, mixtures and articles through the obligations that actually apply.
One project may need registration, restriction screening, Candidate List communications, an article notification or SCIP submission; these are different legal routes. Testing supports particular decisions but does not replace registration or remove a restriction.
Define the REACH work package at intake
A project owner first freezes the assessed scope and records which organisation manufactures, imports or supplies each item in the EEA. An exporter outside the EEA cannot simply assume its laboratory report discharges the importer's duties.
- SKU, formulation or bill of materials (BOM), including component articles, coatings, adhesives and intended release, where relevant.
- Legal entities, supplier chain, production sites, EEA importers, possible only representative and intended uses.
- Substance identity (CAS/EC where applicable), mass and yearly tonnage by responsible entity; supplier SDS and declarations with version dates.
- Launch markets, product variations, existing analytical reports, change history and unresolved supplier disclosures.
Choose the obligation route before ordering tests
Use the same decision register for every material or substance. A positive finding on one route never clears the other routes.
| Product / legal trigger | Execution path and recorded outcome |
|---|---|
| Substance on its own or in a mixture; normally at least 1 tonne/year per manufacturer or importer. | Check identity, aggregation, exemptions and existing coverage; if registration is required, arrange inquiry, data access and a REACH-IT dossier before manufacture/import. Record the legal registrant. |
| Article with a substance intended to be released; relevant substance total over 1 tonne/year. | Assess REACH Article 7(1), including prior registration for that use. Do not treat every ordinary finished article as automatically registrable. |
| Candidate List substance in a constituent article above 0.1% w/w. | Check Article 33 information to recipients and consumer response within 45 days; separately assess Article 7(2) notification (>1 tonne/year, subject to exceptions) and SCIP duties under waste law. |
| Substance or use affected by Annex XVII restrictions or Annex XIV authorisation. | Check the precise entry, product/use scope, conditions, dates and exemptions. Testing, registration or an SVHC declaration alone cannot authorise a prohibited use. |
For complex products, assess the 0.1% Candidate List threshold at constituent-article level, not only against the weight of the whole assembly. No single universal REACH certificate or mandatory test panel applies to every product.
Five handoffs from intake to a release decision
The coordinator controls inputs and handoffs; the legally responsible company remains accountable for its own REACH obligations.
| Work stage | Deliverable and handoff gate |
|---|---|
| 1. Scope lock | Signed SKU/entity/use matrix; flag missing formulation details and stop unsupported clearance claims. |
| 2. Regulatory screening | Per-substance obligations register, Candidate List and Annex XVII/XIV snapshots; identify the legal owner and any route needing filing. |
| 3. Evidence and lab brief | Supplier evidence requests and risk-based sample/test plan; log sample-to-SKU mapping, laboratory methods, detection limits and exceptions. |
| 4. Resolve and submit | Reconcile results; remediate failures, then prepare only applicable REACH-IT, Article 7(2), SCIP or supply-chain outputs; retain acknowledgement/evidence. |
| 5. Release and monitor | Dated decision record showing cleared SKUs, limitations, residual unknowns, document owner and triggers for re-evaluation. |
Targeted testing and evidence traceability
Select analytical methods against an identified substance and legal threshold, not a marketing label. Supplier declarations alone may be insufficient when composition is uncertain; a broad screening result also cannot prove compliance with every restriction.
- Evidence index: item/component ID, supplier, substance/entry checked, document date and source, applicable rule and decision.
- Test brief: rationale for sample selection, relevant material, analyte, method, reporting limit and chain of custody; compare the result with the exact legal condition.
- Exception log: missing BOM, changed coating, inconclusive limit, absent identity or inconsistent documents; allocate corrective action and rerun targeted checks where required.
Dossiers, notifications and supply-chain communication
Where substance registration is required, a designated registrant handles joint-submission/data-sharing issues, prepares the IUCLID dossier and files through ECHA REACH-IT. A non-EEA producer may appoint an eligible EEA only representative for registration responsibilities; this is not an automatic transfer of every REACH or product-law duty.
Do not confuse Article 7(2) notification with Article 33 communication or SCIP reporting. Each has different triggers and records. For an article with Candidate List substances, record recipients' safe-use information and the basis for any notification exemption.
Detailed substance registration workflow; Registration issues for consumer products.
Market-readiness gates and change control
Release is a documented decision per SKU and entity, not an unqualified 'REACH approved' stamp. If a restriction is breached or a required pre-market registration is missing, escalate before placing the affected item on the market.
- Green: obligations identified and supported; applicable submissions and communications completed with traceable evidence.
- Amber: material identity, supplier data or test uncertainty remains; set a hold or expressly limited decision until resolved.
- Change control: reassess after a new supplier, material, formulation, use, importer, annual volume or Candidate List/restriction update.
Where this service stops
This page owns coordination from intake to release and continuing evidence control, not exhaustive registration filing instructions or wider CE/RoHS/other-regime approval. REACH compliance by itself is neither CE marking nor a general EU market-access permit.
Wider EU product market-access services; Separate RoHS compliance route.
Official sources to check
- REACH Regulation (EC) No 1907/2006
- ECHA: registration
- ECHA: Article 33 communications
- ECHA: Article 7(2) notification
- ECHA: Annex XVII restrictions
- ECHA: SCIP information
Frequently asked questions
Does every imported finished product need REACH registration?
No. First decide whether it is an article, mixture or substance. Article registration particularly concerns substances intended for release at the relevant tonnage, with qualifications; separate restrictions and SVHC duties may still apply.
Does a passing SVHC test mean the product is fully REACH compliant?
No. A result covers the sampled materials, analytes and detection limits. Check Annex XVII restrictions, relevant registration, information duties and changes independently.
What happens when a component article exceeds 0.1% SVHC?
Assess Article 33 safe-use communication, possible Article 7(2) notification with its tonnage/exemptions, and the separate SCIP obligation. The whole-product average is not a substitute for component assessment.
Can our non-EU supplier appoint someone to handle everything?
An eligible EEA only representative may undertake specified importer registration obligations if properly appointed and covered. Confirm the exact legal chain, substances, volumes and remaining obligations; a consultant alone is not an only representative.
When must the assessment be repeated?
On relevant supplier, BOM, coating, use, tonnage or regulatory-list changes. Retain dated evidence, affected SKUs and a decision on whether further testing, communication or filing is necessary.