REACH Compliance Explained: What Product Companies Actually Need to Do

REACH compliance is the ongoing obligation to register chemical substances, screen finished products for substances of very high concern (SVHCs), respect Annex XVII restrictions, and – when required – submit data to ECHA's SCIP database. It applies to any company that manufactures, imports, or supplies products on the EU market, regardless of where the company itself is based. The regulation that governs it, Regulation (EC) No 1907/2006, is one of the most consequential pieces of chemical legislation in the world, and for most consumer product companies the operational reality lives not in chemical registration but in the obligations that apply to finished articles – textiles, electronics, toys, cosmetics packaging, furniture, homeware.

Two things make 2026 a heavier REACH year than most. ECHA added two more substances to the Candidate List on 4 February 2026, taking the total to 253 SVHCs. And Annex XVII picks up new enforceable entries later this year, including restrictions on undecafluorohexanoic acid (PFHxA) and related substances applying from 10 October 2026. If your compliance workflow depends on someone manually scanning ECHA bulletins every few months, 2026 will stress-test it.

REACH is the EU regulation that governs how chemicals are produced, placed on the market, and used inside the European Economic Area. The acronym stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. The regulation is Regulation (EC) No 1907/2006, applicable across the EU since 1 June 2007.

The regulation is administered by the European Chemicals Agency (ECHA), headquartered in Helsinki, which maintains the registrations, the Candidate List of SVHCs, the Authorisation List (Annex XIV), the restrictions list (Annex XVII), and the SCIP database. Enforcement, however, sits with each EU Member State – national authorities run inspections, issue penalties, and coordinate through ECHA's Forum for Exchange of Information on Enforcement.

Importantly for product companies: REACH does not only regulate chemicals sold as chemicals. It regulates substances on their own, substances in mixtures, and substances in articles – meaning it reaches into every finished product placed on the EU market.

REACH applies to four types of economic operators, each with distinct obligations:

• Manufacturers – companies that produce chemical substances in the EU
• Importers – companies established in the EU that bring substances, mixtures, or articles from outside the EU onto the EU market
• Downstream users – companies that use a substance, either on its own or in a mixture, in the course of their industrial or professional activities
• Distributors – companies that store and place substances on the market for third parties

For most brands and retailers selling finished consumer products, the operational obligations come primarily from being an importer, a downstream user, or a supplier of articles. The exact classification matters: it determines which obligations apply, who bears the registration cost, and how supplier data has to flow through the chain.

Do non-EU brands need REACH compliance?

Yes – and the route most non-EU manufacturers take is the Only Representative. Under Article 8 of REACH, a non-EU manufacturer or producer of articles may appoint a natural or legal person established in the EU to fulfil the obligations of importers under REACH. The Only Representative takes on all importer duties: registration, safety data sheet provision, record-keeping, and supply-chain information. EU-based importers of that non-EU manufacturer's products are then treated as downstream users rather than importers, which removes the registration burden from them.

Appointing an Only Representative is optional, not mandatory. But without one, every EU importer bringing the non-EU company's products into the bloc has to handle their own registrations and obligations – which quickly becomes unmanageable for brands selling through multiple EU partners.

What's the difference between a "substance" and an "article" under REACH?

A substance is a chemical element or compound – the things that get registered in bulk under Article 6. An article, under REACH Article 3(3), is an object whose function depends more on its shape, surface, or design than on its chemical composition. A T-shirt, a plastic toy, a laptop, a leather sofa – all articles.

This distinction is everything for consumer product companies. You generally don't register articles – you register the substances inside them (and only if you manufacture or import the substance itself above one tonne per year, or if the substance is intended to be released from the article under normal use). What you do for articles is screen them against the Candidate List, respect Annex XVII restrictions, communicate SVHC information down the chain under Article 33, and – where applicable – notify SCIP.

REACH is a large regulation. For most product companies, five concrete obligations carry the weight.

1. Registration – Article 6

Manufacturers and importers of chemical substances in quantities of one tonne or more per year per company must register those substances with ECHA. The registration dossier is submitted electronically via REACH-IT and must contain, for substances in the 1–10 tonnes/year band, the information listed in Annex VII of REACH – physicochemical, toxicological, and ecotoxicological data. Heavier bands (10–100, 100–1,000, above 1,000 tonnes/year) require progressively more information, including chemical safety reports. A substance generally cannot be manufactured, imported, or placed on the EU market until a registration number has been issued.

For most consumer product brands, registration is handled upstream – by chemical suppliers or by the Only Representative of a non-EU manufacturer. But you still need to know which substances in your supply chain are registered, and to request safety data sheets where the regulation requires them.

2. SVHC communication – Article 33

This is the obligation that touches every consumer product company, whether you know it or not. Under Article 33 of REACH, any supplier of an article containing a substance on the Candidate List in a concentration above 0.1% weight by weight (w/w) must provide sufficient information to allow safe use of the article – at minimum, the name of the substance.

Two flavours of this obligation apply in parallel:

• Business-to-business: information flows down the supply chain automatically. Your supplier must tell you, and you must tell your customers.
• Business-to-consumer: on request from a consumer, the supplier has 45 days to respond with the same information.

The 0.1% threshold is calculated at the article level – not at the level of the finished product if the product is made of several articles. A zipper containing cadmium above 0.1% is a separate article from the jacket it's sewn into, and both need to be assessed independently. This is where compliance teams most often trip up.

3. SCIP notification – Waste Framework Directive Article 9(1)(i)

The SCIP database (Substances of Concern In articles as such or in complex objects (Products)) is ECHA's public database of articles containing Candidate List substances above 0.1% w/w placed on the EU market. The notification obligation isn't in REACH itself – it's in Article 9(1)(i) of the Waste Framework Directive 2008/98/EC – but it applies to the same Candidate List substances at the same 0.1% threshold, which is why it sits at the centre of most companies' REACH programmes.

Every EU supplier of an article that triggers the Article 33 threshold must also notify ECHA via SCIP before placing it on the EU market. Importers are exempt from SCIP notification in their capacity as importers – but the moment they become suppliers of those articles inside the EU, the obligation kicks in.

4. Annex XVII restrictions

Annex XVII is the list of outright restrictions – substances that cannot be manufactured, placed on the market, or used under specified conditions, regardless of concentration (in some entries) or above specific thresholds (in most). Entries relevant to consumer product companies include:

• Entries 51, 52, and 72 – phthalates in plasticised materials, with the core restriction at 0.1% by weight individually or in any combination in any plasticised material
• PFHxA entry – undecafluorohexanoic acid, its salts, and PFHxA-related substances, applying from 10 October 2026
• Category-specific limits for textiles intended to be washed during normal use, for childcare articles, and for cosmetics-adjacent products

Annex XVII entries are the most operationally sensitive of all REACH obligations for consumer product brands – they are absolute prohibitions, not communication duties. A product containing a restricted substance above threshold cannot be placed on the market at all, and national authorities can order withdrawal or recall.

5. Authorisation – Annex XIV

A smaller list than Annex XVII, but a heavier obligation where it applies. Annex XIV contains substances that require prior authorisation before they can be placed on the market or used, even for industrial uses. Each entry has two dates:

• A latest application date – the deadline for submitting an authorisation application if you want to continue using the substance past its sunset date
• A sunset date – the date from which placing on the market and use of the substance is prohibited unless an authorisation has been granted

For finished-article brands, direct interaction with Annex XIV is rare. But if a supplier upstream holds (or needs) an authorisation for a substance used in your product, the ripple effect on your supply is very real – which is why authorisation tracking belongs in any serious compliance programme.

ECHA updates the Candidate List twice a year, typically in January and June, though off-cycle updates happen. The February 2026 update added two substances – n-Hexane and 4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol (BPAF) and its salts – bringing the total Candidate List to 253 entries. n-Hexane is notable because it's the first substance added based on neurotoxicity under the "equivalent level of concern" provision, rather than under the classical CMR or PBT criteria. The next update is expected in June 2026.

On the restriction side, 10 October 2026 is the effective date of the PFHxA restriction, which covers PFHxA, its salts, and PFHxA-related substances in certain uses. PFAS restrictions more broadly are accelerating: a separate Annex XVII entry on PFAS in firefighting foams introduces compliance triggers in late 2026, including a labelling requirement for foams above a 1 mg/L sum-of-PFAS threshold.

REACH doesn't sit in a silo. For product companies, it overlaps with at least four other regimes:

• GPSR – General Product Safety Regulation (EU) 2023/988, applicable since 13 December 2024, requires products to be safe. Chemical content is explicitly part of that assessment, which means REACH screening feeds directly into GPSR compliance.
• CE marking – REACH sits alongside CE marking rather than inside it. A product can carry the CE mark under the New Legislative Framework while still failing REACH Annex XVII, and vice versa.
• Digital Product Passport (DPP) – the data you already assemble for SCIP, Article 33, and Annex XVII screening is a strong foundation for the structured product records that DPP will require as ESPR delegated acts are adopted.
• UK REACH – since Brexit, the UK operates its own REACH regime (a mirror of the EU text with separate registrations, Candidate List decisions, and enforcement). Companies selling into both GB and the EU need to manage both regimes, and divergence between them is growing.

For a quality or regulatory manager picking up REACH compliance from scratch, the work breaks into five concrete steps.

What is the difference between REACH and RoHS?

REACH is a horizontal chemical regulation applying to virtually all substances and articles on the EU market. RoHS (Directive 2011/65/EU) is a product-specific regime that restricts specific hazardous substances in electrical and electronic equipment (EEE). A laptop must comply with both: RoHS for restricted substances like lead and certain phthalates in its EEE components, and REACH for SVHC communication, SCIP notification, and any Annex XVII entries that apply beyond what RoHS already covers.

Does REACH apply to non-chemical products like textiles and toys?

Yes. REACH applies to substances in articles – meaning finished goods. Textiles, toys, electronics, furniture, leather goods, jewellery, and homeware are all in scope. The main obligations for article suppliers are Article 33 communication, SCIP notification, and respecting any Annex XVII entries applicable to their product category.

What happens if I miss an SVHC communication deadline?

Article 33 is enforced at the Member State level. Penalties vary significantly – from administrative fines in the low thousands to, in some jurisdictions, criminal sanctions. More commonly, the operational risk is that a customer or marketplace requests an SVHC declaration you can't produce, which leads to delisting or blocked shipments. The 45-day consumer response window is often the first point of friction teams encounter.

Do I need to notify SCIP if I already comply with Article 33?

Yes – they are separate obligations. Article 33 is about communicating information to customers; SCIP is about submitting data to ECHA's public database. The trigger – an SVHC above 0.1% w/w in an article placed on the EU market – is the same, but the obligation is discharged in two different places. Most compliance programmes build a single screening pipeline that feeds both outputs.

What are the penalties for REACH non-compliance?

Each EU Member State sets its own penalties, which must be "effective, proportionate, and dissuasive" under the general EU law requirement. In practice, fines range from administrative penalties to substantial amounts – for example, up to €4 million and/or imprisonment for certain infringements in some Member States – and several jurisdictions include criminal liability for serious or repeated breaches.

For a brand with a stable, narrow product range, REACH compliance is demanding but manageable – a quality manager, a spreadsheet, a set of supplier declarations, and a recurring check against each Candidate List update. For brands launching hundreds of new products a year across dozens of markets, the picture changes. Every Candidate List update (253 SVHCs and counting) has to be traced back through the product portfolio. Every new Annex XVII entry has to be checked against every active SKU. Every supplier change has to be re-screened.

This is the compliance reality Complir was built for. Structured product records per SKU, continuous monitoring of the Candidate List and Annex XVII, automatic flagging of affected products when a regulation changes, and audit-ready Article 33 and SCIP documentation generated from one source of truth – so your team spends time on decisions, not on manual screening.

If your team is chasing Candidate List updates across hundreds of SKUs and running SVHC screening in spreadsheets, see how Complir automates REACH monitoring across your product portfolio.

Sources & References

• Regulation (EC) No 1907/2006 – REACH full text on EUR-Lex
• Directive 2008/98/EC – Waste Framework Directive (SCIP basis) on EUR-Lex
• European Chemicals Agency – Understanding REACH
• ECHA – Candidate List of substances of very high concern for Authorisation
• ECHA – Summary of obligations resulting from inclusion of SVHCs in the Candidate List
• ECHA – SCIP database
• ECHA – Authorisation List (Annex XIV)
• ECHA – Substances restricted under REACH (Annex XVII)
• European Commission – REACH Regulation
• European Commission – REACH enforcement

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements may vary by product category, market, and specific circumstances. Consult with a qualified legal professional for compliance guidance specific to your situation.