What Is REACH and Why It Concerns You
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is Regulation (EC) No. 1907/2006 of the European Parliament and of the Council, which entered into force on June 1, 2007, and has since formed the backbone of European chemical legislation.
The aim of REACH is to ensure a high level of protection of human health and the environment from the risks of chemical substances, while supporting the competitiveness and innovation of the European chemical industry. The regulation shifted the burden of proof onto manufacturers and importers — they must demonstrate that the substance they place on the market is safe, rather than authorities having to prove the opposite.
REACH is built on four pillars that give the regulation its name:
Registration
Manufacturers and importers must register every substance produced or imported in quantities above 1 ton per year. Registration includes documentation of the substance's properties, uses, and risks.
Evaluation
ECHA and member states evaluate registration dossiers and may request additional tests or data if a risk is suspected.
Authorisation
The most hazardous substances (SVHCs included in Annex XIV) may not be used after the so-called sunset date without special authorization from the European Commission.
Restriction
Annex XVII establishes specific bans or limits on the use of substances, even those that have otherwise passed registration — typically due to a specific risk in a given application.
Why REACH Concerns Buyers Specifically
A buyer at a manufacturing company is not just someone who negotiates price and delivery times. They are the first line of defense against compliance risk. If you purchase a chemical from a supplier whose registration is not in order, whose safety data sheet is outdated, or who failed to inform you of the presence of an SVHC substance, the risk falls on your company as a downstream user — not just the supplier.
An improper purchase can mean: production stoppage due to a substance being withdrawn from the market, penalties from a ČIŽP inspection, reputational damage with customers requiring REACH compliance certification, or even civil liability in the event of harm to employees' health.
The Role of ECHA
ECHA (European Chemicals Agency), based in Helsinki, manages the registration database, the SVHC Candidate List, the list of restrictions and authorizations, and provides publicly accessible information on registered substances at echa.europa.eu. For buyers, this is the first place to verify the status of any chemical substance.
Who's Who in the Supply Chain
REACH defines the roles of participants in the supply chain and assigns different obligations to each role. As a buyer, you need to know what role you are dealing with, since this determines what documents and guarantees you can request from the supplier.
Manufacturer
A company based in the EU that manufactures or extracts the substance. Bears full registration responsibility for all produced tonnage above 1 t/year. Must prepare a safety data sheet and, where applicable, a chemical safety report (CSR) for substances above 10 t/year.
Importer
A company based in the EU that imports a substance or mixture from a third country. If the importer buys from a manufacturer outside the EU, they bear the registration obligation themselves — unless the foreign manufacturer appoints an Only Representative.
Only Representative (OR)
A representative based in the EU appointed by a non-EU manufacturer to fulfill the registration obligation on their behalf. If you buy directly from a non-EU manufacturer, verify whether the OR has a valid registration — otherwise you, as the importer, are the one who must register.
Downstream User
A company in the EU that uses a substance or mixture in manufacturing, formulation, or processing — typically your own position as a manufacturing company purchasing chemicals. You have no registration obligation, but you must comply with the conditions of use stated in the SDS and exposure scenarios and inform the supplier of new uses.
Distributor
A company that only stores and resells the substance or mixture, without modifying its composition. Has no registration obligation but must ensure the transfer of the current SDS and SVHC information to the next links in the chain.
Practical Risk for Buyers
If you purchase directly from a manufacturer outside the EU (China, India, USA) without an EU intermediary, you automatically become an importer with all registration obligations — including the need to register the substance with ECHA. This risk can be eliminated by requiring an Only Representative on the supplier's side.
Safety Data Sheets (SDS) — What You Must Check
A Safety Data Sheet (SDS) is the fundamental document that a supplier must provide for every hazardous substance or mixture. The structure of the SDS is harmonized according to Annex II of the REACH regulation and always has 16 sections in a precisely defined order.
| Section | Content — what to check as a buyer |
|---|---|
| 1 | Identification of the substance/mixture and company — name, REACH registration number, supplier contact, and emergency phone number |
| 2 | Hazard identification — CLP classification, H-statements, pictograms |
| 3 | Composition/information on ingredients — CAS numbers, concentrations, presence of SVHC above 0.1% |
| 4 | First aid measures |
| 5 | Firefighting measures |
| 6 | Accidental release measures |
| 7 | Handling and storage — check compliance with your storage conditions |
| 8 | Exposure controls / personal protection — DNEL, PNEC values |
| 9 | Physical and chemical properties |
| 10 | Stability and reactivity |
| 11 | Toxicological information |
| 12 | Ecological information — biodegradability, ecotoxicity |
| 13 | Disposal considerations — waste code per the Waste Catalogue |
| 14 | Transport information — ADR/RID classification |
| 15 | Regulatory information — REACH, CLP status, national regulations |
| 16 | Other information — issue/revision date, SDS version |
Extended Safety Data Sheet (eSDS)
For substances registered above 10 t/year that require a Chemical Safety Report (CSR), the supplier must attach Exposure Scenarios to the SDS — creating an extended SDS (eSDS). The exposure scenario describes the conditions for safe use: specific operating conditions, risk management measures, and identified uses covered by the registration.
Key Check for Buyers
If your planned use of the substance does not match any of the exposure scenarios in the eSDS, you must inform the supplier — either they will extend the registration to cover your use, or you yourself will need to prepare your own chemical safety report as a downstream user. Ignoring this step is one of the most common compliance gaps.
Validity and Updates of the SDS
The SDS must be updated without undue delay if new risk information emerges, the classification changes, the substance is added to the SVHC Candidate List, or an authorization is granted or refused. As a buyer, you should:
- →Check the revision date in section 16 with every new delivery
- →Request an updated SDS at least once a year, even if the supplier does not proactively send updates
- →Archive all SDS versions for at least 10 years after the substance is no longer used (requirement of Art. 36 REACH)
- →Verify that the SDS is in the local language — the supplier is obliged to provide the SDS in the official language of the member state where the substance is placed on the market
Registration Numbers & Tonnage
Every registered substance receives a REACH registration number from ECHA in the format 01-XXXXXXXXXX-XX-XXXX, which must be stated in section 1.1 of the safety data sheet. This number is your first verification that the substance has actually been registered.
The scope of the manufacturer's or importer's obligations depends on the tonnage band — the higher the quantity of substance produced or imported annually, the more extensive the required documentation and testing.
| Tonnage Band | Required Documentation | Chemical Safety Report (CSR) |
|---|---|---|
| 1–10 t/rok | Basic physicochemical, toxicological, and ecotoxicological data | No (only if the substance is classified as hazardous) |
| 10–100 t/rok | Extended testing — mutagenicity, acute toxicity, biodegradability | Yes, mandatory |
| 100–1000 t/rok | Additional studies on long-term toxicity, reproductive toxicity | Yes, mandatory, extended with exposure scenarios |
| nad 1000 t/rok | Full scope of studies including carcinogenicity and developmental toxicity | Yes, the most extensive, detailed exposure scenarios for all identified uses |
How to Verify Registration in the ECHA Database
On the echa.europa.eu portal, in the "Registered Substances" section, you can search for a substance by name, CAS number, or EC number. The database displays the registration status, tonnage band, CLP classification, and any inclusion on the SVHC Candidate List or Annex XVII/XIV.
Practical Tip
Before signing a framework agreement with a new supplier, always request a copy of the registration or at least confirmation of the registration number from ECHA. For importers outside the EU, have them provide proof of a contract with an Only Representative — without it, the registration may be invalid and you become the liable importer.
SVHC — Substances of Very High Concern
SVHC (Substances of Very High Concern) are substances with properties of extreme concern: carcinogenic, mutagenic, or toxic for reproduction (CMR category 1A/1B), persistent, bioaccumulative, and toxic (PBT), very persistent and very bioaccumulative (vPvB), endocrine disruptors, or substances with other serious and irreversible effects on health or the environment.
The Candidate List
ECHA maintains a public SVHC Candidate List, typically updated twice a year (usually in June and December). The list currently contains more than 240 substances and continues to grow. Inclusion on the Candidate List does not in itself ban the substance but triggers specific information obligations.
Notification Obligation Above 0.1%
If an article contains a substance from the Candidate List at a concentration greater than 0.1% by weight, the supplier must inform the buyer of the presence of the SVHC and safe use — regardless of whether the substance is classified as hazardous. Consumers also have the right to request this information within 45 days free of charge (Art. 33 REACH).
The Authorisation List (Annex XIV)
The most serious substances from the Candidate List gradually move to Annex XIV (the Authorisation List). For these substances, a so-called sunset date is set — a date after which use of the substance is prohibited unless the manufacturer or downstream user obtains a specific authorization from the European Commission for the given use. Substances on Annex XIV include, for example, lead chromate, certain phthalates (DEHP, DBP, BBP, DIBP), or chromium trioxide.
Authorization is granted for a limited period (typically 4–12 years), and the applicant must demonstrate that the risk is adequately controlled or that the socio-economic benefit outweighs the risks and no suitable alternative exists.
How Buyers Can Monitor SVHC Status
We recommend establishing regular checks (e.g., quarterly) of key purchased substances against the current Candidate List at echa.europa.eu/candidate-list-table. For critical suppliers, request a contractual commitment to immediate notification if any of the supplied substances is added to the Candidate List or Annex XIV.
Restrictions — Annex XVII
Annex XVII of the REACH regulation contains a list of substances whose manufacture, placing on the market, or use is prohibited or restricted for specific applications — regardless of whether the substance is otherwise duly registered. Unlike authorization, a restriction does not concern the substance as a whole but specific uses or concentration limits.
| Substance / Group | Restriction | Relevance for Industrial Buyers |
|---|---|---|
| NMP (N-metylpyrolidon) | Ban on use above the derived DNEL value without risk management since 2020 | Common solvent in cleaning products and coatings — requires SDS with DNEL and measures stated |
| DMF (N,N-dimetylformamid) | Similar restriction to NMP, harmonized classification as reproductively toxic | Used as a solvent in syntheses and in polyurethane production |
| Chrom VI (chromany, dichromany) | Banned in articles in contact with skin above 3 mg/kg, restricted in cement and plating | Critical for electroplating shops and metal surface treatment |
| Ftaláty DEHP, DBP, BBP, DIBP | Banned in toys and childcare articles above 0.1%, DEHP/DBP/BBP on the authorization list | Plasticizers in PVC — required check for imported plastic components |
| Formaldehyd | Emission limits from wood materials (class E1), restrictions in textiles and cosmetics | Preservative in adhesives, resins, and textile treatments |
| PFAS / PFOA (per- a polyfluoroalkylové látky) | PFOA banned since 2020; a broader restriction of the entire PFAS group has been proposed, with gradual implementation expected from 2026–2027 | Used in low surface tension coatings, firefighting foams, textile impregnations — monitor legislative developments |
| Diisokyanáty | Mandatory worker training since August 2023 for industrial and professional use above 0.1% | Key for manufacturers of polyurethane foams and adhesives |
Upcoming PFAS Restriction
Five European agencies (including the German, Dutch, Danish, Swedish, and Norwegian authorities) submitted a proposal in 2023 for a broad restriction of the entire PFAS group (more than 10,000 substances). The proposal is undergoing evaluation by ECHA committees, and a final decision by the European Commission is expected gradually from 2026 with transition periods by sector. If you purchase coatings, impregnations, or firefighting foams containing fluorinated compounds, actively monitor developments — the restriction may fundamentally change the availability of these products.
CLP Regulation & Labeling
The CLP Regulation (EC) No. 1272/2008 (Classification, Labelling and Packaging) complements REACH and introduces the globally harmonized GHS (Globally Harmonized System) for the classification and labeling of chemical substances into the EU. While REACH addresses the registration and risks of a substance as such, CLP determines how a substance or mixture should be classified according to hazard and how the packaging should be labeled.
Hazard Pictograms
CLP defines nine standard pictograms (a red diamond with a black symbol) — e.g., flame (flammability), skull and crossbones (acute toxicity), corrosion (skin/metal corrosion), exclamation mark (irritation), health hazard (chronic effects), or tree and fish (environmental hazard).
Hazard and Precautionary Statements
Hazard statements (H-statements) describe the type and degree of hazard, for example H302 (harmful if swallowed) or H350 (may cause cancer). Precautionary statements (P-statements) indicate recommended safety measures, for example P280 (wear protective gloves) or P273 (avoid release to the environment). Both sets of statements must be stated on the package label and in section 2 of the safety data sheet.
The Relationship Between CLP and REACH
CLP classification is one of the inputs for REACH registration — if a substance is classified as hazardous, this triggers an obligation for the manufacturer/importer to prepare a Chemical Safety Report (CSR) even below the 10 t/year tonnage limit. Companies must also report the classification to the Classification and Labelling Inventory maintained by ECHA.
As a buyer, you should always check the compliance of the label with the data in SDS section 2 upon receipt of goods — a mismatch is one of the most common formal deficiencies found during ČIŽP inspections.
Practical REACH Compliance Checklist for Buyers
We recommend carrying out the following steps before every new purchase of a chemical substance or mixture and with every change of supplier.
1. Request the current SDS
Verify the revision date (section 16), the language of the document, and compliance with the current CLP classification.
2. Verify the REACH registration number
Check the format of the number in section 1.1 and verify it in the ECHA database (echa.europa.eu/registered-substances).
3. Check the supplier's tonnage band
Make sure the registered tonnage band covers the volume you plan to purchase — if you order a large quantity from a supplier registered only in a low band, a mismatch may arise.
4. Check the SVHC status
Compare the substance's CAS number with the current SVHC Candidate List and Annex XIV (authorization).
5. Check restrictions under Annex XVII
Verify whether a specific use restriction relevant to your application applies to the substance.
6. Verify the supplier's role in the chain
Are they a manufacturer, importer, distributor? If outside the EU, do they have an appointed Only Representative with a valid registration?
7. Check exposure scenarios (for eSDS)
Does your planned use match one of the listed exposure scenarios? If not, inform the supplier of the new use.
8. Incorporate REACH clauses into the contract
Contractually oblige the supplier to immediately notify you of a classification change, addition to the SVHC list, or loss of registration.
9. Establish internal records
Keep the SDS, registration confirmation, and correspondence with the supplier for at least 10 years after the substance is no longer used.
10. Plan a periodic review
Set up a quarterly or semi-annual check of key substances against the updated SVHC Candidate List.
What to Do During an Audit or Inspection
In the Czech Republic, supervision of REACH and CLP compliance is carried out by the Czech Environmental Inspectorate (ČIŽP) in cooperation with the Czech Customs Administration (for imports from third countries) and the State Office for Nuclear Safety (for specific substances). Inspections can be planned or random, or triggered by a complaint or incident.
What Inspectors Typically Check
- →The existence and up-to-dateness of safety data sheets for all stored hazardous substances
- →Compliance of package labels with the SDS classification (CLP compliance)
- →Records of REACH registration numbers and their validity in the ECHA database
- →The presence of SVHC substances in purchased products and fulfillment of the information obligation to customers
- →Compliance with exposure scenario conditions (risk management measures, PPE)
- →Records and handling of hazardous waste generated during the use of the substance
- →Training of employees working with hazardous substances (especially for diisocyanates since 2023)
Documentation You Should Always Have on Hand
Most Common Findings During Inspections
Based on practical experience, the most common deficiencies include: missing or outdated SDS, SDS only in English, mismatch between the package label and the SDS classification, missing records of SVHC notifications, and absence of proof of an Only Representative for imports outside the EU. Penalties under Act No. 350/2011 Coll. on Chemical Substances and Chemical Mixtures can reach several million CZK, and in serious cases, operations may be halted.
Frequently Asked Questions
What does the abbreviation REACH mean?+
As a buyer, how do I verify that a substance is registered under REACH?+
What is SVHC and how often is the list updated?+
What is the difference between restriction and authorization under REACH?+
As a downstream user, do I need to register the substances I purchase myself?+
What are the consequences for a company that fails to comply with REACH during an inspection?+
Need Assurance That Your Chemicals Are REACH Compliant?
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