What Is REACH 223 Compliance and Why Does It Matter for EU Imports?

What Does REACH 223 Compliance Actually Mean?

If you sell chemicals, components, textiles, electronics, furniture, toys, packaging, or other finished goods to Europe, reach 223 compliance may appear in buyer emails or supplier forms. It is not a separate EU law. In normal trade work, it points to the EU REACH Candidate List after the European Chemicals Agency, known as ECHA, updated it on 17 January 2022 and said the list had 223 entries. For wider import control, this subject fits under product Compliance, because many buyers now want chemical proof before goods leave the factory.

The point to watch is the number. The 223 count is old. ECHA’s 4 February 2026 Candidate List update stated that the list contains 253 entries. So when a buyer asks for REACH 223 compliance, they may actually mean current SVHC disclosure, notification, restriction, and record duties under REACH. Source: ECHA Candidate List updates, 17 January 2022 and 4 February 2026.

It Refers to a Historic Candidate List Count

The Candidate List covers substances of very high concern, usually called SVHCs. These substances may be carcinogenic, toxic to reproduction, persistent, bioaccumulative, endocrine disrupting, or raise a similar level of concern. In January 2022, ECHA added four substances and the list reached 223 entries. Some entries cover chemical groups, so the actual number of chemicals affected can be higher than the entry count.

It Does Not Replace EU REACH Regulation EC 1907/2006

REACH itself is Regulation (EC) No 1907/2006. It deals with registration, evaluation, authorisation, and restriction of chemicals. The number 223 only described one point in time for the SVHC list. A product can pass an old 223-entry check and still fail a newer Candidate List, Annex XVII restriction, or buyer specification.

It Still Triggers Current Supply Chain Duties

For exporters, the job is not to remember an old list number. You need a working process that checks the latest Candidate List, finds risky materials, gets supplier evidence, and gives the EU importer enough data for its own legal duties. This is where many small orders get stuck. The product may be acceptable, but the paperwork is too general.

Which Products Create the Biggest REACH Risk?

REACH risk follows the material, not only the product name. A stainless-steel bolt, a PVC cable, a painted zipper puller, and a PU leather bag may be in the same shipment, but the chemical risk is not the same. Eurostat reported on 26 March 2026 that China was the EU’s largest source of goods imports in 2025, worth €559.4 billion and 22.3% of total EU imports. That trade volume is one reason EU buyers ask about chemical compliance early, especially for products with plastics, coatings, dyes, metals, rubber, adhesives, and flame retardants. Source: Eurostat, EU Trade in Goods 2025 release, 26 March 2026.

Articles with Plastic Rubber or Coatings

Soft plastics, artificial leather, rubber grips, coated fabrics, painted metal, and foams need careful checking. Phthalates, short-chain chlorinated paraffins, PAHs, lead, cadmium, and certain flame retardants have shown up many times in market surveillance cases. A phone cable sheath or a handbag handle can carry more REACH risk than the main metal or textile part. This is why buyers often ask for material-level evidence instead of a simple product-level statement.

Electrical Products Fashion Items and Toys

ECHA’s Forum REF-10 project report, published on 13 December 2023, checked 2,407 products during its 2022 operational phase. The overall non-compliance rate was 18%. For articles it was 20%, and for Article 33 communication duties linked to Candidate List substances, the identified non-compliance rate was 30%. Electrical products had a 52% non-compliance rate in the checked article groups, while toys were 23%, sport articles 18%, and fashion 15%. Source: ECHA Forum REF-10 Project Report, 13 December 2023.

Chemicals Mixtures and Intended Release Articles

If you export glue, paint, ink, detergent, lubricant, resin, fragrance, or similar mixtures, the EU importer may have registration or Safety Data Sheet duties. The exact duty depends on the substance, volume, hazard class, and role in the supply chain. If an article is made to release a substance, such as a scented toy or fragrance article, the rules can also go beyond normal article communication. The one-tonne-per-year registration threshold for substances remains a basic REACH trigger, although exemptions and role details still need to be checked.

What Are Your Main Duties Under REACH 223 Compliance?

Start by putting each product into the right REACH category: substance, mixture, article, or complex object. A bicycle, coffee machine, garment, or LED lamp is often a complex object made from many smaller articles. This matters because the 0.1% SVHC threshold is checked at article level, not only against the weight of the whole finished product.

The 0.1 Percent SVHC Communication Rule

Under REACH Article 33, a supplier of an article containing a Candidate List substance above 0.1% weight by weight must give recipients enough information for safe use. At a minimum, the name of the substance must be provided. Consumers can ask for this information, and the supplier must reply within 45 days. Source: EUR-Lex consolidated REACH Regulation and ECHA Candidate List obligation guidance.

The Six Month Article Notification Window

Article 7(2) adds another duty for EU producers and importers of articles. They must notify ECHA when a Candidate List substance is present above 0.1% weight by weight and the total is more than one tonne per producer or importer per year, unless a valid exemption applies. ECHA states that notification is due no later than six months after the substance joins the Candidate List. Source: ECHA notification guidance for substances in articles.

SCIP Reporting for Articles on the EU Market

Since 5 January 2021, suppliers placing articles on the EU market must submit information to ECHA’s SCIP database when those articles contain Candidate List SVHCs above 0.1% weight by weight. SCIP comes from waste law, but it uses REACH Article 33 information. A non-EU exporter may not be the legal SCIP submitter. Even so, the EU buyer will need your material data to file the record correctly. Source: ECHA SCIP database guidance.

How Should You Collect Supplier Data That Buyers Trust?

A one-line supplier statement saying the goods are REACH compliant is not strong evidence. It may help close an order at the start, but it usually does not stand up well in a buyer audit. Better evidence links each material to a substance list, date, concentration result, test method, and responsible supplier. Small factories can manage this too, as long as someone keeps the file in order. It is basic paperwork, but it prevents long email chains later.

A Bill of Materials at Article Level

Build a bill of materials that breaks the finished product into real articles. For a backpack, that may mean outer fabric, lining, zipper tape, zipper puller, coating, logo patch, foam padding, buckle, thread, and packaging. For an electrical product, split cable jackets, solder, printed circuit boards, housings, gaskets, adhesives, and labels. This article-level view makes it easier to see which parts need testing or supplier follow-up.

CAS and EC Numbers Instead of Generic Promises

Ask suppliers for CAS numbers, EC numbers, substance names, material grades, and the Candidate List date used in their declaration. Group entries can cover salts, isomers, and reaction masses, so a quick “not listed” answer may not be enough. If the supplier cannot name the chemical, the declaration should not be treated as solid evidence. In practice, buyers trust named substances and dated lists much more than broad promises.

Test Reports for High Risk Materials

Testing every screw is not a good use of budget. Use a risk-based plan instead. Test high-risk materials first: soft PVC, black recycled plastic, artificial leather, rubber, coated metal, jewellery parts, painted toys, electrical solder, and dark dyes. Choose reports from competent labs, check that the tested sample matches current production, and make sure the report date is not older than the material change. See also: Customs.

What Documents Should You Prepare Before Shipment?

Good REACH files are short, clear, and up to date. They should help the EU importer answer a buyer, customs broker, market authority, or consumer without chasing several factories in different time zones. The file does not need a fancy format. It needs clear product and material details.

REACH Declaration with Current Candidate List Date

Your REACH declaration should state the product model, item code, supplier, factory, date, Candidate List version, and whether any SVHC is present above 0.1% weight by weight at article level. If a substance is above the threshold, name it and provide safe-use information. Avoid calling a 2026 shipment REACH 223 compliant unless the buyer clearly asks for a historical 2022 list check. Most current buyers expect the latest ECHA list.

Safety Data Sheets for Substances and Mixtures

For substances and mixtures, keep Safety Data Sheets in the EU format when required. Article 31 of REACH sets SDS duties for hazardous substances and mixtures, among other cases. Finished articles normally do not need SDS documents, but buyers may still ask for safe-use information or material declarations. Do not use an SDS for a chemical raw material as full proof that a finished article is compliant; it is only one part of the file.

Correct Product Labels and Buyer Records

Chemical products may also need CLP labels, hazard pictograms, language checks, and batch traceability. For articles, keep purchase orders, supplier declarations, lab reports, photos of tested samples, material specifications, and shipment records in one file. If a market authority asks questions six months later, a clear record is much better than a last-minute supplier promise. It also helps the buyer reply faster and with fewer doubts.

How Can Importers Reduce Holds Rejections and Cost?

Most REACH problems are not unusual. They are often simple issues: an old declaration, a missing CAS number, a changed pigment, a recycled plastic lot, or a supplier who copied last year’s form. The better fix is a routine check before shipment, not after the goods arrive in Hamburg, Rotterdam, Antwerp, or another EU port.

Map the EU Importer and Only Representative Role

The EU importer often carries the legal burden for substances imported into the EU. A non-EU manufacturer can appoint an Only Representative for certain REACH registration duties, but this does not remove the need for Article 33 or SCIP data along the supply chain. Your sales contract should say who collects substance data, who files where needed, and who updates documents after Candidate List changes. Without that split of work, the same questions usually come back at shipment time.

Screen Suppliers Before Purchase Orders

Put chemical data requests into the purchase order stage. Ask for the current Candidate List date, article-level SVHC status, lab reports for risky materials, and a promise to inform you before changing raw materials. If the supplier pushes back, narrow the request to the parts that actually carry risk. This usually gets better answers than sending a 40-page form to every supplier.

Keep a Change Log After Every ECHA Update

ECHA commonly updates the Candidate List twice a year, though the timing can change. Keep a simple change log with the update date, new substances checked, affected product families, supplier replies, and revised declarations. A 30-day refresh after each ECHA update is a practical target for many importers. It is not perfect, but it is far better than waiting for a buyer complaint.

FAQ

Q1: Is REACH 223 Compliance Still Current in 2026? A: The phrase is still used, but the 223 count is not current. It refers to the Candidate List count after ECHA’s 17 January 2022 update. ECHA’s 4 February 2026 update stated that the list contains 253 entries.

Q2: Does a Product Pass REACH If Every SVHC Is Below 0.1%? A: It may pass Article 33 and SCIP disclosure triggers, but that is not the full REACH check. Annex XVII restrictions, SDS duties for mixtures, registration duties, buyer limits, and other EU rules may still apply.

Q3: Can a Non-EU Exporter Submit SCIP Directly? A: SCIP duties generally sit with EU suppliers placing articles on the EU market. A non-EU exporter usually supports the EU importer by providing article-level substance data, safe-use information, and updated declarations.

Q4: How Often Should You Update a REACH Declaration? A: Update it after every ECHA Candidate List change, any material change, any supplier change, and any new test result. For active EU shipments, a six-month review cycle is a workable baseline.

Q5: Is a Lab Test Report Enough for Buyer Approval? A: Not by itself. A useful file also needs a product match, sample photo or description, tested material, Candidate List date, test scope, supplier declaration, and a clear statement at article level.