EU-wide REACH enforcement project Focus on imported products

EU law protects human health and the environment against risks caused by chemicals, while promoting competitiveness in the chemical industry. Under a two-pillar set of rules[1], the EU imposes numerous obligations upon importers of chemical substances, mixtures and articles, amongst:

  • Notification of chemical substances, mixtures and articles introduced on the market,
  • Registration of substances imported for a volume superior to 1T/year,
  • Prior authorization for certain substances harming for health or having hazardous nature,
  • Adapting the labeling and packaging systems of chemical substances and mixtures

Those rules are directly applicable in all 27 Member States and to all importers.


Future focus on imported goods

The Enforcement Forum of the European Chemicals Agency (ECHA), responsible for harmonizing the enforcement of EU chemicals legislation, agreed to focus its next project on the control of imported products: substances, mixtures and articles.

In a recent pilot project, the ECHA found that almost 1 in 4 of inspected imported chemical products did not meet with the requirements set by the REACH. As there is higher rates of non-compliance among imported products than EU made products, the entry point into the European market of imported products is strategic. The Forum therefore agreed that the best way to improve REACH compliance is to spot the breaches at the border, instead of once the product has entered the market. The inspection phase will start in 2024, for one year, after the planning phase, that is set to take place in 2023.

Further controls at customs borders are expected, in implementation of this enforcement project. Companies must anticipate and double check their compliance.


Our team has a strong experience in advising international traders in managing their REACH compliance obligations

We are at your disposal for any further information.

[1] REACH Regulation (Regulation n° 1907/2006 of 18 December 2006 concerning the Registration, Evaluation, Authorization and Restrictions of Chemicals) and CLP Regulation (Regulation n°1272/2008 concerning the Classification, Labelling and Packaging of substances and mixtures)