REACH compliance: a practical checklist for importers

When you import a chemical into the EU or EEA, the compliance obligation lands on you, not on your Chinese supplier. The supplier can give you data, but the registration duty, the communication duty and the liability are yours.

This is a checklist of what to collect and what to verify, not legal advice. Confirm the specifics with your own regulatory consultant for the substances you actually buy.

The obligation sits with the importer

Under REACH, a company established in the EU that imports a substance above one tonne per year generally has to register it, or rely on a registration already made for that substance by an EU manufacturer or importer. The non-EU supplier cannot register on your behalf. It can appoint an only representative, which changes who holds the registration duty.

Before anything else, confirm who is the importer of record and whether an only representative is in place.

What to request from the supplier before the first shipment

• Full substance identity, including CAS and EC numbers, and the purity range
• A current safety data sheet in the format and language your member state requires
• A statement on SVHC content, with the concentration in the mixture if any candidate list substance is present
• The identity of the manufacturer, not only the trading entity
• Confirmation of whether the substance has been registered, and under whose name

Registration, pre-registration and the candidate list

Registration follows tonnage bands starting at one tonne per year. The candidate list of substances of very high concern is updated periodically and is separate from registration: a substance can be registered and still appear on the list.

If a candidate list substance is present above 0.1 percent by weight in a mixture you place on the market, information duties apply to your customers. That threshold is per article or mixture, not per shipment, and it catches buyers who only check the headline purity.

Where importers get caught out

• Relying on an SDS from a previous buyer that is several years old
• Treating a supplier's registration number as covering their own import volume
• Missing a candidate list update because the supplier's document was issued before the change
• Importing a different grade than the one covered by the documentation, for example a technical grade instead of a registered one

A reusable document checklist

Keep a folder per supplier per substance containing the current SDS, the COA for each batch, the SVHC statement, the manufacturer identity, and a dated note on registration status. Review the SDS and the candidate list at least once a year, and again whenever you change supplier or grade.

Documentation that cannot be traced to a manufacturer and a date is not evidence. It is paperwork.