REACH and CLP in Automotive: Compliance Guide

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Vehicle manufacturing and the production of their components are among the most highly regulated industrial sectors, where compliance with chemical legislation plays a key role. The REACH and CLP regulations impose obligations not only on manufacturers of chemical substances but also on their users – including automotive manufacturers and parts suppliers. Non-compliance can lead to legal penalties, production delays, or product recalls. This article explains how to correctly assess raw materials, maintain documentation, and minimize risks when working with chemicals in the automotive sector.

REACH and CLP: The fundamental framework for the automotive industry

The automotive industry is one of the sectors with the strictest requirements for chemical safety and legislative compliance. The REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and CLP (Classification, Labelling and Packaging) regulations form the fundamental pillars that determine which chemical substances may be used in the production of vehicles and their components. REACH focuses on the registration and evaluation of substances, while CLP ensures their correct classification, labelling, and packaging in accordance with the Globally Harmonized System (GHS). For manufacturers and suppliers in the automotive sector, this means an obligation to verify that all raw materials used – from metal alloys to polymeric additives – comply with the requirements of these regulations.

An important aspect is the monitoring of so-called substances of very high concern (SVHC), which are listed on the REACH Candidate List. These substances are subject to an authorisation process, and their use is only possible based on an exemption or after obtaining permission. Automotive manufacturers and their suppliers must regularly update their supply chains and require confirmation from chemical suppliers regarding compliance with REACH and CLP, including safety data sheets (SDS) and labels with appropriate GHS markings.

Safety Data Sheets (SDS) and Their Role in the Supply Chain

A Safety Data Sheet (SDS) is a key document that provides comprehensive information on the chemical properties, risks, and safe handling of raw materials. In the automotive industry, an SDS must be available for every chemical substance or mixture used in the production process, in its current version and in the language of the country where the substance is used. The SDS must contain 16 mandatory sections, including information on physico-chemical properties, toxicological data, first aid measures, and disposal instructions.

For vehicle manufacturers and their suppliers, it is crucial that SDS contain accurate and complete data, especially regarding worker exposure or the environment. For example, in the case of additives for plastics or coatings, it must be clearly stated whether the substance contains SVHC or is subject to restrictions under Annex XVII of the REACH Regulation. Chemical suppliers should be able to provide not only SDS but also supplementary technical documentation, such as test reports or certificates of compliance with industry standards.

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Classification and labelling of chemicals according to CLP/GHS

The CLP Regulation introduces a unified system for the classification and labelling of chemical substances and mixtures, based on the Globally Harmonized System (GHS). For the automotive industry, this means that all raw materials, from lubricants to adhesives, must be properly classified according to their hazardous properties, such as toxicity, flammability, or corrosivity. The classification must be indicated on labels and in safety data sheets, with the use of standardized pictograms, signal words ("Danger" or "Warning"), and standard hazard statements (H-phrases) and safety instructions (P-phrases) being mandatory.

In practice, manufacturers and suppliers in the automotive sector must ensure that all chemical packaging is correctly labelled in accordance with the CLP Regulation. This applies not only to raw materials supplied for production but also to finished products containing chemical substances, such as paints or cleaning agents used in service centres. Incorrect or incomplete labelling can lead to legal penalties and jeopardize the safety of workers and end users.

Practical steps to ensure compliance with REACH and CLP in automotive manufacturing

Ensuring compliance with the REACH and CLP Regulations requires a systematic approach and collaboration across the entire supply chain. The first step is to map all chemical raw materials used in production and verify their registration status in the REACH database. Manufacturers should require confirmation of substance registration from their suppliers and regularly update information on any changes in legislation, such as new substances added to the SVHC candidate list.

Another important measure is the implementation of internal processes for managing safety data sheets and labels. This includes regular checks of SDS up-to-date status, employee training in the safe handling of chemicals, and the introduction of a system for monitoring worker exposure. In the automotive industry, where highly specialized materials such as plastic additives or corrosion inhibitors are often used, it is also advisable to collaborate with chemical safety experts who can provide consultations on process optimization and risk minimization.

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REACH and Specific Requirements for Automotive Suppliers: Substance of Very High Concern (SVHC)

In the automotive industry, compliance with REACH regulations plays a key role not only from a legislative perspective but also in terms of sustainability and responsibility toward customers. Special attention must be paid to substances listed on the Substances of Very High Concern (SVHC) list. These substances, such as certain phthalates, brominated flame retardants, or chromium compounds, are subject to strict restrictions and reporting obligations. Vehicle manufacturers and their suppliers must ensure that no vehicle component contains SVHC in a concentration exceeding 0.1% by weight at the level of individual parts.

For automotive suppliers, this means careful monitoring of the supply chain and demanding transparent information from sub-suppliers. It is essential to have a system in place for tracking material composition and regularly updating the database of chemical substances used. If an SVHC is detected in a product, it is necessary to promptly inform the European Chemicals Agency (ECHA) and take measures to replace the substance with a safer alternative. This process requires close cooperation between technical, procurement, and legal departments.

CLP and Safety in Handling Chemical Raw Materials in Production Halls

The classification, labelling, and packaging of chemical substances according to the CLP Regulation (Classification, Labelling and Packaging) is crucial in the automotive industry to ensure worker safety and prevent accidents. Production halls where adhesives, coatings, lubricants, or cleaning agents are processed must be equipped with clear labelling of all chemical substances in accordance with GHS (Globally Harmonized System) standards. This includes the use of warning symbols, signal words ("Danger" or "Warning"), and standardized hazard statements (H-phrases) and safety instructions (P-phrases).

For automotive manufacturers, it is important not only to label packaging correctly but also to ensure employee training in the handling of chemical substances. Workers should be familiar with the risks associated with specific substances, such as flammability, toxicity, or corrosivity. Furthermore, emergency procedures must be prepared in case of spills or exposure. Regular reviews of safety measures and updates to Safety Data Sheets (SDS) in accordance with legislative changes are essential for long-term compliance with CLP.

Documentation and Audit Readiness: How to Demonstrate Compliance with REACH and CLP During Inspections

In the automotive industry, regular inspections by state authorities or customers are a standard part of operations. Demonstrating compliance with REACH and CLP regulations requires systematic documentation and audit readiness. A key document is the Safety Data Sheet (SDS), which must be available for all chemical substances and mixtures used in production. The SDS must not only be up-to-date but also correctly archived and easily retrievable in case of an inspection.

In addition to SDS, it is important to maintain records of substance usage, including quantities, purposes of use, and suppliers. For substances subject to authorization or restrictions under REACH, it is necessary to demonstrate that all obligations have been met, such as reporting to the SCIP database (Substances of Concern In articles, as such or in complex objects – Products). To facilitate audits, it is recommended to implement a digital system for chemical management, which enables quick searching and generation of required reports. Preparation for inspections should also include internal audits and employee training to ensure they can answer inspectors' questions and demonstrate familiarity with legislative requirements.

Do You Need to Verify Raw Material Compliance with Legislation?

GCG Group provides up-to-date Safety Data Sheets (SDS) and technical documentation for every supplied raw material in compliance with REACH and CLP. Our experts will advise you on material selection and interpretation of requirements for your specific application. Contact us – or browse our catalogue of over 1,300 products right away.