March 11, 2025

REACH Compliance: Managing Chemical Risks in Consumer Goods

REACH compliance means meeting the applicable requirements of the European Union’s REACH Regulation (EC) No 1907/2006, which governs the manufacture, import, supply, and use of chemical substances in the European market.

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. The regulation is administered at EU level by the European Chemicals Agency (ECHA) and applies to chemical substances on their own, in mixtures, and in many finished products, legally referred to as articles.

For consumer goods, REACH compliance commonly involves checking whether materials contain restricted substances under Annex XVII, identifying Substances of Very High Concern (SVHCs) on the Candidate List, meeting applicable communication and notification obligations, and maintaining evidence that supports compliance.

Products commonly affected include:

Textiles and apparel
Footwear
Toys and childcare products
Electrical and electronic products
Furniture and home goods
Plastic and rubber products
Jewellery and accessories
Packaging and other consumer goods

The exact requirements depend on the product, its materials, the substances involved, how it is used, and the role of each company within the supply chain.

What is REACH Compliance?

REACH compliance refers to fulfilling the chemical regulatory obligations that apply under Regulation (EC) No 1907/2006.

There is no single REACH certificate or universal test that makes every product REACH compliant. Different obligations apply depending on whether a business manufactures or imports substances, supplies mixtures, produces or imports articles, or distributes products within the EU.

For finished consumer products, three areas are particularly important:

Annex XVII restrictions
Candidate List SVHC requirements
Supply-chain communication and applicable notification obligations

Companies dealing directly with chemical substances may also have registration and authorisation obligations.

A REACH compliance assessment therefore begins by identifying the product’s materials and chemical composition and determining which provisions of REACH apply.

Who Needs to Comply With REACH?

REACH establishes obligations for several participants in the European supply chain.

Manufacturers

EU manufacturers producing chemical substances may have registration and other obligations depending on the substance and annual quantity.

Manufacturers of finished articles must also consider restrictions and requirements relating to substances incorporated into those articles.

Importers

EU importers can carry significant REACH responsibilities because they introduce substances, mixtures, or articles manufactured outside the EU into the European market.

The obligations depend on what is being imported and the substances involved.

Downstream Users

Companies using chemicals in industrial or professional activities may have obligations concerning safe use, exposure scenarios, safety information, and authorised or restricted substances.

Suppliers of Articles

Suppliers of products classified as articles may have communication obligations when an article contains an SVHC included on the Candidate List above the applicable threshold.

Non-EU Manufacturers

REACH directly places many obligations on EU-based economic operators. However, manufacturers outside the EU are still commercially affected when supplying products or substances to European customers.

A non-EU manufacturer of substances may appoint an Only Representative established in the EU to fulfil certain importer obligations under REACH.

For finished consumer goods, overseas suppliers are also commonly required to provide material information, declarations, test reports, or other documentation requested by their European customers.

Key REACH Compliance Requirements

REACH contains several regulatory mechanisms. Understanding their different purposes is essential when assessing chemical compliance.

REACH Registration

Companies manufacturing or importing a substance into the EU in quantities of one tonne or more per year generally need to determine whether registration is required.

Registration involves providing ECHA with information about the substance, including its properties, uses, hazards, and measures for controlling identified risks.

Registration requirements primarily concern chemical substances and should not be confused with finished-product chemical testing.

REACH Evaluation

ECHA and EU Member States can evaluate registration information and substances to determine whether further information or regulatory action is necessary.

Evaluation is therefore primarily a regulatory process within the broader REACH system.

REACH Authorisation

Certain SVHCs may eventually be included in Annex XIV, the Authorisation List.

After the applicable sunset date, listed substances generally cannot be used or placed on the market for a use covered by the authorisation requirement unless that use has been authorised or an exemption applies.

The Candidate List and Authorisation List should therefore be treated separately. Inclusion on the Candidate List does not automatically mean that a substance is prohibited.

ECHA Authorisation List

REACH Restrictions Under Annex XVII

Annex XVII establishes restrictions on the manufacture, placing on the market, or use of specified substances.

Each restriction has its own conditions. Requirements may depend on factors such as:

Substance concentration
Product material
Intended use
Consumer accessibility
Exposure conditions
Product category

A product can therefore comply with one Annex XVII entry while still requiring evaluation against other applicable entries.

For consumer products, Annex XVII is one of the most important parts of a practical REACH compliance assessment.

What Are Substances of Very High Concern (SVHCs)?

Substances of Very High Concern, commonly called SVHCs, are substances identified under REACH because they meet specific hazard criteria.

Examples of qualifying properties include substances that are:

Carcinogenic, mutagenic, or toxic for reproduction (CMR)
Persistent, bioaccumulative and toxic (PBT)
Very persistent and very bioaccumulative (vPvB)
Of an equivalent level of concern

SVHCs identified through the REACH process can be added to the Candidate List.

The Candidate List is important because inclusion can immediately create legal obligations for suppliers of articles.

REACH Article 33 Requirements

Article 33 establishes communication requirements for Candidate List substances in articles.

When an article contains a Candidate List substance at a concentration above 0.1% weight by weight (w/w), suppliers must provide recipients with sufficient information to allow safe use of the article. At minimum, this includes the name of the relevant substance.

Consumers can also request information about Candidate List substances in articles. The supplier must provide the applicable information within 45 days and free of charge.

This makes accurate material and substance information particularly important throughout the supply chain.

REACH Article 7(2) Notification

SVHCs can also trigger notification obligations to ECHA under Article 7(2).

EU and EEA producers or importers of articles generally need to assess this requirement when both of the following conditions are met:

A Candidate List substance is present above 0.1% w/w in the relevant article.
The substance is present in those articles in quantities exceeding one tonne per producer or importer per year.

Certain exemptions can apply, including circumstances where the substance has already been registered for that use.

This notification requirement is separate from the Article 33 communication obligation.

SCIP Notification and REACH

Companies supplying articles in the EU should also consider the SCIP database requirements established under the EU Waste Framework Directive.

Articles placed on the EU market containing Candidate List SVHCs above 0.1% w/w can trigger SCIP information requirements.

SCIP is closely connected with REACH Candidate List information, although the notification requirement originates from the Waste Framework Directive.

This distinction is important when preparing a complete chemical compliance program.

Common REACH Restricted Substances in Consumer Products

The substances requiring assessment depend heavily on the materials and intended use of the product.

Some chemical groups frequently considered during consumer product compliance assessments include:

Substance / Chemical Group	Products or Materials Commonly Assessed
Phthalates	Plastics, PVC, synthetic materials, coatings
Azo colorants	Textiles and leather
Chromium VI	Leather articles
Nickel	Metal parts intended for direct and prolonged skin contact
PAHs	Rubber and plastic components
Certain heavy metals	Jewellery, coatings, plastics and other materials
Certain flame retardants	Textiles, plastics and treated materials
Certain organotin compounds	Plastics, coatings and treated materials

The presence of a substance does not automatically establish non-compliance. The relevant Annex XVII entry, scope, concentration limit, material, use, and applicable exemptions must be considered.

REACH Compliance for Consumer Products

REACH applies across a wide range of consumer product categories, although the substances requiring attention vary considerably.

Textiles and Apparel

Textile products can contain chemicals introduced through dyes, printing, finishing, coatings, waterproofing treatments, synthetic materials, and accessories.

Depending on the product and materials, assessments may cover substances such as:

Restricted azo colorants
Certain phthalates
Certain heavy metals
Formaldehyde where relevant to applicable requirements
SVHCs in materials and components

Chemical control should consider the individual materials used throughout the garment, including fabrics, prints, coatings, plastic components, and metal accessories.

Footwear

Footwear often combines leather, textiles, rubber, plastics, adhesives, coatings, metal accessories, and synthetic materials.

Common areas considered during a footwear REACH assessment include:

Chromium VI in leather
Restricted azo colorants in leather and textiles
Phthalates in plasticised materials
PAHs in rubber and plastic components
Nickel release from applicable metal components
Candidate List SVHCs

Because a single shoe may contain many different materials, material-level risk assessment can help determine an appropriate testing scope.

Toys and Children’s Products

Toys can contain plastics, coatings, textiles, rubber, metals, adhesives, and other materials subject to REACH restrictions.

Depending on the product, REACH assessments may include phthalates, PAHs, certain colorants, metals, and other regulated substances.

Toy manufacturers must also consider separate EU toy safety requirements where applicable.

Electrical and Electronic Products

Electronic products may contain plastics, cables, coatings, adhesives, solder, metal components, and flame-retarded materials.

REACH can apply to these materials independently of other chemical regulations affecting electrical and electronic equipment.

Electrical products sold in Europe may therefore require assessment under both REACH and RoHS where applicable. For a detailed comparison, see our guide to REACH vs RoHS.

Furniture and Home Goods

Furniture and household products can contain wood-based materials, textiles, artificial leather, plastics, coatings, adhesives, foam, rubber, and metal components.

The relevant chemical assessment depends on the materials used and the specific restrictions applicable to them.

How to Determine Whether a Product Is REACH Compliant

Determining REACH compliance requires a structured assessment because different substances and materials can be subject to different requirements.

1. Identify Product Materials and Components

Break the product down into its individual materials and components.

For example, a shoe may contain:

Leather upper
Textile lining
Rubber outsole
Plastic eyelets
Metal accessories
Adhesives
Coatings

This material breakdown helps identify which chemical restrictions may apply.

2. Review Applicable Annex XVII Restrictions

Check whether substances associated with each material are covered by REACH Annex XVII.

The conditions of each applicable restriction should be reviewed carefully because limits and scope vary between entries.

3. Check the Current Candidate List

Determine whether the product or its component articles contain Candidate List SVHCs.

Because the Candidate List changes over time, assessments should use the current ECHA list.

4. Review Supplier Documentation

Relevant documentation may include:

Material specifications
Chemical declarations
Supplier REACH declarations
Safety Data Sheets where applicable
Bills of materials
Previous laboratory reports

Supplier documentation helps identify known chemical risks and determine where additional verification may be needed.

5. Establish a Risk-Based Testing Plan

Testing should target substances relevant to the product’s materials and regulatory requirements.

A textile component, leather component, plastic component, and metal component may require different analyses.

6. Evaluate Communication and Notification Obligations

Where Candidate List substances are identified above applicable thresholds, Article 33, Article 7(2), and SCIP obligations should be evaluated as relevant.

7. Maintain Compliance Records

Keep supporting documentation so that compliance decisions can be traced back to material information, supplier evidence, regulatory assessments, and test results.

REACH Testing for Consumer Products

REACH testing is commonly used to verify whether specific materials comply with applicable chemical restrictions.

There is no universal REACH test covering every requirement under the regulation.

A testing program should be developed according to:

Product type
Material composition
Applicable Annex XVII entries
Known chemical risks
Supplier information
Customer requirements
Previous testing history

For example, leather footwear may require testing for chromium VI, while plasticised components may require phthalate analysis.

This risk-based approach helps focus laboratory testing on substances relevant to the materials being assessed.

REACH Compliance Documents

A REACH compliance file may contain several types of supporting information.

Common documents include:

Bill of materials
Material specifications
Supplier declarations
REACH declarations
Laboratory test reports
Safety Data Sheets where applicable
SVHC declarations
Chemical composition information
Risk assessments
Article 33 communication records where required
Applicable notification records

The appropriate documentation depends on the product and the obligations involved.

A generic supplier statement claiming that a product is REACH compliant may provide limited evidence when it does not identify the substances, materials, regulatory scope, or supporting test data considered.

REACH Compliance Checklist

A practical product compliance review can use the following checklist:

Compliance Area	Key Question
Product materials	Have all relevant materials and components been identified?
Annex XVII	Have applicable restrictions been reviewed?
Candidate List	Has the current SVHC Candidate List been checked?
Supplier information	Are material and chemical declarations available?
Testing	Has testing been performed where verification is required?
Article 33	Are communication obligations applicable?
Article 7(2)	Does an ECHA notification requirement apply?
SCIP	Is a SCIP submission required?
Documentation	Is sufficient compliance evidence maintained?
Regulatory updates	Are changes to relevant REACH requirements being monitored?

Common REACH Compliance Mistakes

Several issues regularly weaken product chemical compliance programs.

Treating REACH as a Single Test

REACH covers many substances and regulatory mechanisms. A single laboratory test report does not automatically demonstrate compliance with every REACH obligation.

Testing Every Product for the Same Chemical List

Testing requirements should reflect the product’s materials and relevant chemical risks. Applying an identical test package to every product can overlook material-specific requirements.

Relying Only on Supplier Declarations

Supplier declarations are useful documentation, but their reliability depends on the information and controls supporting them.

Testing may be appropriate when material composition is uncertain, the product presents a higher chemical risk, or independent verification is required.

Confusing the Candidate List With Annex XVII

These lists perform different regulatory functions.

Annex XVII establishes specific restrictions on substances.

The Candidate List identifies SVHCs and can trigger communication, notification, and other obligations.

Assuming SVHC Means Banned

Candidate List inclusion does not automatically prohibit a substance.

The concentration, product structure, applicable REACH obligations, and any other relevant regulatory measures must be evaluated.

Ignoring Components Within Complex Products

A complex product may contain multiple component articles. Chemical assessment should consider the structure and materials of the product at the appropriate article level.

REACH vs RoHS Compliance

REACH and RoHS both regulate hazardous substances in the European market, but their scope and legal requirements differ.

REACH	RoHS
Broad chemical regulation	Applies specifically to electrical and electronic equipment within its scope
Covers substances, mixtures and articles	Restricts specified hazardous substances in electrical and electronic equipment
Includes registration, authorisation, restrictions and SVHC obligations	Establishes maximum concentration values for restricted substances in homogeneous materials
Applies across many industries	Focused on the electrical and electronics sector

Some electrical and electronic products must comply with both frameworks.

For more information, see REACH vs RoHS: Key Differences.

REACH compliance requires accurate information about the substances and materials used in a product, together with regular review of applicable restrictions and Candidate List obligations.

A structured process should include material identification, supplier documentation, regulatory assessment, risk-based testing, and record maintenance. When materials, suppliers, formulations, or regulatory requirements change, the compliance assessment should be reviewed to confirm that the available evidence remains valid.