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(EC) No 1907/2006

In force

REACH Regulation (article-supplier duties)

The EU's chemicals regulation. For physical-product (article) sellers the practical duties are: communicating Candidate List substances of very high concern (SVHCs) above 0.1% down the supply chain and to consumers, notifying ECHA in some cases, and respecting the Annex XVII restrictions. Full chemical registration applies to substance manufacturers/importers, not typical article sellers.

Read the official text

Applies to

Suppliers (producers, importers, distributors) of articles — physical objects whose shape/surface/design determines their function — placed on the EU/EEA market. Focus here is on article-level duties, not the registration regime for chemical substances.

Key obligations

  1. 01Article 33(1): if an article contains a Candidate List SVHC above 0.1% weight by weight, provide recipients (businesses in the supply chain) with sufficient information for safe use — at minimum the name of that substance. This applies per article within a complex product.source
  2. 02Article 33(2): on request from a consumer, provide the same safe-use information (at minimum the substance name) within 45 days, free of charge.source
  3. 03Article 7(2): EU producers/importers of articles must notify ECHA when a Candidate List substance is present above 0.1% w/w AND its total quantity in those articles exceeds 1 tonne per producer/importer per year — no later than 6 months after the substance is added to the Candidate List. Notification is not required where exposure of humans and the environment can be excluded.source
  4. 04Notify articles containing Candidate List SVHCs above 0.1% w/w to ECHA's SCIP database (a duty under the Waste Framework Directive, submitted via ECHA).sourceUnverified — check source
  5. 05Ensure articles comply with the Annex XVII restrictions on substances in consumer articles (e.g. limits on lead, cadmium, nickel release in jewellery, phthalates in toys/childcare articles).sourceUnverified — check source

Conformity routes

  • No conformity assessment / self-managed complianceREACH has no CE-style conformity assessment or notified bodies for articles. Duties are self-executing: screen your bill of materials against the Candidate List (updated roughly twice a year) and Annex XVII, keep supplier declarations, and respond to information requests.source

Documentation

  • Supplier declarations / full material disclosuresEvidence that Candidate List SVHCs are below 0.1% w/w per article, or the basis of your Article 33 communications.source
  • Article 33 safe-use communicationsRecords of the information passed to recipients and provided to consumers within the 45-day deadline.source

Marking requirements

  • REACH requires no product marking for articles. Communication duties are informational (supply-chain and on-request consumer information), not label-based.source

Penalties

Enforcement and penalties are set nationally by each Member State; several countries impose substantial fines or criminal sanctions for REACH breaches. Amounts vary by country.sourceUnverified — check source

Further guidance

Applies to these product types

Frequently asked

I sell finished products, not chemicals — does REACH really apply to me?+

Yes, in a limited way. You don't register chemicals, but you must know whether any Candidate List substance of very high concern exceeds 0.1% by weight in any article you supply, tell business customers proactively, and answer consumer requests within 45 days.

What is the Candidate List?+

ECHA's list of substances of very high concern (SVHCs) — substances that are carcinogenic, mutagenic, toxic for reproduction, persistent, or of equivalent concern. It is updated periodically, so compliance screening has to be repeated as new substances are added.

When do I have to notify ECHA about an SVHC in my products?+

Under Article 7(2), when both thresholds are met: the substance is above 0.1% w/w in the articles and totals more than 1 tonne per year across your articles. The notification is due within 6 months of the substance joining the Candidate List, unless exposure can be excluded.

Does the 0.1% threshold apply to the whole product or each part?+

Each article. Following the EU Court of Justice's 'once an article, always an article' ruling, the 0.1% concentration is assessed against each component article of a complex product, not the assembled product's total weight.

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