REACH stands for Registration, Evaluation, Authorisation and restriction of Chemicals, and it's the EU's central law for managing chemical substances. It runs on Regulation (EC) No 1907/2006, and its guiding idea is simple: industry, not the authorities, has to prove that a substance can be used safely. The slogan that sums it up is "no data, no market". No registration, no place on the EU market. If you import chemicals, or products that contain them, REACH almost certainly touches you somewhere.
The law is administered by the European Chemicals Agency (ECHA) in Helsinki, and it applies to substances on their own, substances in mixtures, and in some cases substances in articles (finished products).
What REACH actually covers
Three situations fall under REACH:
- A substance on its own, for example a drum of a single industrial chemical.
- A substance in a mixture, such as a paint, adhesive or cleaning product.
- A substance in an article, when it's intended to be released from that article under normal use (and over one tonne per year), or when an article contains a substance of very high concern.
The volume is what triggers most duties, and you aggregate across all three uses to decide whether you cross a threshold.
The registration duty: who and when
Registration is the backbone of REACH. Anyone who manufactures or imports a substance into the EU at one tonne or more per year has to register it with ECHA before placing it on the market. The registration dossier sets out the substance's identity, its properties, the hazards, and how it can be used safely. Below one tonne a year there's no registration duty, but the other parts of REACH (restrictions, SVHC communication) can still apply.
This is where importers need to pay attention. Under REACH the EU importer is the one who carries the registration duty for a substance or mixture coming in from outside the EU. A supplier in China or the US has no legal standing under REACH on its own; the obligation lands on whoever brings the goods across the EU border.
The only representative: shifting the duty off the importer
There's an alternative built into the system. A non-EU manufacturer can appoint an only representative (OR), an entity established in the EU that takes over the REACH obligations for the imported substances. The OR does the registration and carries the compliance duties that would otherwise fall on each individual importer.
The practical effect matters for the supply chain. When a proper OR is in place and has registered the substance, the EU companies buying that substance no longer count as importers under REACH; they become downstream users, with much lighter obligations. So when you buy a chemical from a non-EU producer, one of the first questions to ask is: is there an only representative, and does the registration cover your tonnage and use? If not, the registration duty is yours.
A few things worth knowing about the OR construction:
- One OR can represent several non-EU companies, each as a separate legal entity in ECHA's systems.
- The OR role is fixed; it can't later be flipped to "importer" or "manufacturer" for the same registration.
- The OR must be a real EU-established entity, not just a mailbox, and it has to keep information on the importers it covers.
SVHC, the candidate list, authorisation and restrictions
Beyond registration, REACH has a hazard-control layer for the worst substances.
Substances of very high concern (SVHC) are substances that are carcinogenic, mutagenic or toxic for reproduction (CMR), or persistent, bioaccumulative and toxic (PBT/vPvB), or of equivalent concern. Once identified, an SVHC goes on the candidate list. Being on the candidate list already creates duties, in particular communication down the supply chain and notification when an article contains the substance above 0.1% by weight.
From the candidate list, ECHA recommends priority substances for the Authorisation List (Annex XIV). After a substance's "sunset date", you can't use it in the EU unless you've obtained a specific authorisation from the European Commission. That's a deliberately heavy process, designed to push the market toward safer alternatives.
Separately, restrictions (Annex XVII) limit or ban the manufacture, placing on the market or use of specific substances, on their own or in mixtures and articles. A restriction applies to everyone, no individual decision needed; if your product hits a restricted substance above the stated limit, it simply can't go on the EU market in that form.
The safety data sheet: the document that travels with the chemical
The safety data sheet (SDS), sometimes still called a material safety data sheet, is the core REACH communication document. For hazardous substances and mixtures, the supplier has to provide an SDS to professional recipients, built to a fixed 16-section structure: identification, hazards, composition, first aid, handling and storage, exposure controls, and so on. For registered substances above ten tonnes a year, exposure scenarios are attached as an annex (an "extended SDS").
For an importer, the SDS is the practical anchor. It tells you what you're dealing with, whether the substance is registered, restricted or an SVHC, and how the information flows on to your own customers. When chemicals arrive without a proper SDS, that's a red flag worth chasing before the goods move further. The same document also feeds your transport classification, which brings us to the boundary.
Where REACH ends and transport rules begin
A common mix-up: REACH is not the same thing as dangerous-goods transport law. REACH is about market access and registration, whether a substance may be placed on the EU market and under what conditions. The rules for actually moving hazardous cargo, by road (ADR), sea (IMDG) or air (IATA), are a separate regime with their own classes, packing groups, UN numbers and documentation.
A product can be fully REACH-compliant and still be strictly regulated for transport, or be low-risk for transport yet face heavy REACH duties. You have to satisfy both, independently. For the transport side, the classification, packaging and documentation of hazardous shipments, see Dangerous Goods.
How Nexport Logistics fits in
We're a freight forwarder and customs broker, not a REACH consultancy, and we won't pretend to be one. What we do is flag the REACH angle before it becomes a problem at the border: when an import looks like a substance, a mixture or an SVHC-bearing article, we ask the questions that matter early. Is there a registration or an only representative covering this? Is there a usable safety data sheet? Is the substance restricted or on the way to authorisation? Getting those answers up front keeps your Customs clearance clean and your import into the Netherlands on schedule.
Nexport Logistics works under the FENEX conditions, with our own customs declarants, and you track every shipment in the Nexportal portal. Importing chemicals and unsure where REACH lands? Email info@nexportlogistics.nl and we'll walk through it with you.
Official sources: ECHA — Understanding REACH · ECHA — Registration · ECHA — Only representative · ECHA — Authorisation List (Annex XIV) · ECHA — Substances restricted under REACH (Annex XVII) · EUR-Lex — Regulation (EC) No 1907/2006. Related: Dangerous Goods · Customs · Importing Into The Netherlands · Import Certificates