REACH compliance list for importers and product teams

What a REACH compliance list should do

A REACH compliance list is more than a spreadsheet of banned chemicals. For importers, exporters and product teams, it should work as a control document that links each product, material, component and supplier declaration to the main EU REACH obligations. The list should help answer four practical questions: whether substances may require registration, whether any substance appears on the Candidate List of substances of very high concern, whether Annex XIV authorisation issues may apply, and whether Annex XVII restrictions affect placing the product on the EU market.

As of September 2026 checks against ECHA’s public tables, the Candidate List showed 253 entries, with the most recent additions dated 4 February 2026. That makes version control and supplier follow-up essential, especially for companies trading articles, mixtures or chemical-containing goods into the EU.

For trade teams, the value of a REACH compliance list is operational. It turns a complex chemicals regulation into a repeatable evidence workflow. It should not replace legal review or laboratory assessment, but it can reduce the risk of late shipment holds, incomplete customer declarations and outdated supplier certificates. This guide is written for import and export readers who need a usable framework for product screening. For broader regulatory topics, visit our Compliance section.

The main REACH lists you need to separate

Many compliance errors start with treating “the REACH list” as a single list. In practice, importers need to separate several regulatory tools because they create different duties, timelines and evidence requirements. A substance appearing on one list does not automatically mean a product is banned, but it may trigger communication, notification, authorisation or restriction obligations.

The European Commission describes restrictions as measures that may limit or ban the manufacture, placing on the market or use of a substance. It also states that restrictions setting conditions for placing substances on the market apply to domestic production and imports. This distinction matters in day-to-day trade work: an imported article may be outside an authorisation duty in some circumstances, while still being blocked or limited by an Annex XVII restriction.

A practical REACH compliance list template

A useful REACH compliance list should combine product data, chemical identity and regulatory status in one controlled file. The format may be a spreadsheet, product lifecycle management field, supplier portal or compliance database. The important point is traceability: every conclusion should lead back to evidence.

At minimum, include these fields:

• Product name, SKU, model number and product family.
• Article, mixture or substance classification for REACH screening purposes.
• Bill of materials, including components, coatings, adhesives, inks, plastics, textiles, metals, batteries and packaging if relevant.
• Supplier name, manufacturing site and declaration date.
• Substance identifiers such as CAS number, EC number and substance name where available.
• Candidate List status and list version or check date.
• Annex XIV status, including sunset date if relevant.
• Annex XVII restriction entry, concentration limit, scope and applicable exemptions where relevant.
• SVHC concentration result at the article level, not only at the finished product level.
• Supporting evidence, such as supplier declaration, safety data sheet, test report, material declaration or technical file reference.
• Action required, owner and next review date.

The article-level concentration field deserves close attention. ECHA guidance explains that the 0.1% weight by weight threshold for Candidate List substances applies to each article supplied. For complex objects, such as electronics, machinery, furniture or assemblies, teams should not rely only on the total weight of the finished product if a smaller component contains an SVHC above the threshold.

How to screen products step by step

Start with product classification

First decide whether the item is a substance, a mixture, an article or a complex object made of multiple articles. This classification affects the rest of the checklist. A paint, adhesive or cleaning fluid is usually treated differently from a metal bracket, textile bag, circuit board or assembled machine. Borderline cases should be documented because a change in classification can change the evidence you need.

Map suppliers to materials

Supplier declarations are most useful when they are tied to specific materials, versions and product scopes. A general letter stating that a company is “REACH compliant” is weak evidence if it does not identify the product scope, Candidate List version, issue date, responsible entity and concentration basis. Ask suppliers to confirm whether the declaration covers the exact SKU, all colors, all coatings and all subcomponents. If a product has alternate factories or substitute materials, those alternatives should be screened separately.

Check the Candidate List first

The Candidate List is usually the first REACH compliance list reviewed for articles because it can trigger immediate supply-chain duties. When a Candidate List substance is present above 0.1% weight by weight in an article, suppliers must provide sufficient information to allow safe use to business recipients. Consumers may also request information, and the response duty is commonly managed through internal customer service and compliance procedures.

Check Annex XVII before shipment

Annex XVII is critical because restrictions can directly affect market access. A product may have no reportable SVHC above 0.1% and still fail REACH because a restricted substance exceeds a specific limit. Common trade-sensitive areas include certain phthalates in plasticised materials, nickel release from articles intended for direct and prolonged skin contact, asbestos, certain PAHs, tattoo inks, lead in specific uses, and intentionally added microplastics in covered product categories. The exact restriction entry, scope and transition date matter more than a broad substance name match.

Check Annex XIV where EU use is involved

Annex XIV matters most when an EU entity uses a listed substance or places it on the market as a substance or in a mixture after the sunset date. If the substance is embedded in an imported article, the authorisation duty may not apply in the same way. The product can still face other REACH controls, customer phase-out requirements or future restrictions. Importers should therefore treat Annex XIV matches as escalation items rather than simple pass-or-fail results.

Thresholds and duties that should appear in your checklist

Your REACH compliance list should translate legal triggers into operational decision points. The following items are especially important for import/export teams.

• One tonne per year: EU manufacturers and importers generally need to register substances manufactured or imported at one tonne or more per year per company, unless an exemption applies.
• 0.1% weight by weight for Candidate List substances in articles: This threshold is central to Article 33 communication duties and SCIP reporting. It should be assessed at article level.
• More than one tonne per year for SVHCs in imported or produced articles: REACH Article 7 notification may be relevant if a Candidate List substance is present above 0.1% weight by weight and the total amount of the substance exceeds one tonne per producer or importer per year, unless exposure can be excluded or another exemption applies.
• SCIP reporting from 5 January 2021: Under the Waste Framework Directive, companies supplying articles on the EU market that contain Candidate List substances above 0.1% weight by weight must submit information to ECHA’s SCIP database.
• Annex XVII limits: These limits vary by entry. Some are concentration limits, some are use bans, and some include transition periods or exemptions.

Because thresholds differ by obligation, the same product can require one action but not another. For example, a component containing an SVHC above 0.1% may require supply-chain communication even if the importer does not cross the one-tonne annual threshold for Article 7 notification. A restriction limit may also be lower, higher or structured differently from the SVHC reporting threshold.

Evidence that supports a defensible REACH file

A REACH compliance list is only as strong as the documents behind it. In trade operations, stronger files usually combine supplier data, regulatory screening and targeted testing where the risk justifies it. The right evidence depends on the product category, material risk and customer requirement.

Useful evidence may include: See also: Customs.

• Full material declarations for high-risk or high-volume products.
• Supplier declarations tied to the current Candidate List version and exact product scope.
• Safety data sheets for substances and mixtures, checked for consistency with the shipped product.
• Test reports from competent laboratories for restricted substances in relevant materials.
• Engineering drawings or bills of materials showing article-level structure.
• SCIP dossier references where reporting has been completed.
• Change-control records when suppliers, formulations, pigments, plasticisers, coatings or factories change.

Testing should be risk based. It is rarely efficient to test every product for every REACH substance. Instead, identify material-risk combinations: phthalates in soft PVC, nickel in metal accessories touching skin, PAHs in rubber or plastic components, azo colorants in dyed textiles, lead or cadmium in coatings, and PFAS-related concerns in water-, oil- or stain-resistant materials. The checklist should show why a test was selected, which component was tested and whether the test method matches the regulatory question.

Common mistakes in REACH compliance lists

The first common mistake is accepting old declarations without checking list dates. Because the Candidate List is updated periodically, a declaration that was acceptable last year may be incomplete today. A good checklist should show the version or check date and trigger supplier revalidation when ECHA updates the list.

The second mistake is confusing certification with compliance. REACH does not operate as a universal product certificate issued once for all markets. A supplier letter can support the file, but the importer still needs to know what it covers, what it excludes and whether the conclusion fits the exact product placed on the EU market.

The third mistake is screening only against finished-product weight. For complex objects, a small component may exceed the 0.1% SVHC threshold even if the average concentration across the full product is far below it. This can affect Article 33 communication and SCIP reporting.

The fourth mistake is ignoring Annex XVII because no SVHC was found. Restrictions are separate from Candidate List reporting. A product may be free of reportable SVHCs and still fail a specific restriction entry.

The fifth mistake is treating non-EU exporters as if they can always complete REACH duties directly. ECHA explains that obligations often fall on the EU-based importer or an only representative where REACH allows that structure. Exporters outside the EU still play a critical role by providing composition data, evidence and timely updates to their EU customers.

Review cadence and ownership

A REACH compliance list should have an owner and a review schedule. For stable, low-risk goods, a periodic review may be enough. For chemical mixtures, consumer goods, electronics, textiles, toys, personal accessories and products using coatings or plasticisers, review should also be triggered by supplier changes, formulation changes, new colors, new factories, regulatory updates or customer complaints.

Practical ownership usually sits across procurement, product engineering, quality, logistics and compliance. Procurement obtains supplier declarations. Engineering confirms material structure. Quality manages testing and nonconformities. Logistics ensures the correct product version ships. Compliance maintains the regulatory list, escalation decisions and customer communication templates.

The best REACH compliance list is not a static archive. It is a live trade-control tool that shows what was checked, what evidence supports the decision, who approved the result and when the next review is due. That discipline helps importers respond faster to customer requests, regulatory updates and shipment questions without rebuilding the file from scratch.

Frequently asked questions

Is a REACH compliance list the same as the SVHC Candidate List?

No. The SVHC Candidate List is one important source, but an importer’s REACH compliance list should also cover Annex XVII restrictions, Annex XIV authorisation issues, registration triggers, SCIP duties and supplier evidence.

Does REACH apply to finished articles?

Yes, certain REACH obligations can apply to articles. Candidate List communication, SCIP reporting, Article 7 notification and Annex XVII restrictions may all be relevant depending on the substance, concentration, article structure, use and market placement.

How often should a REACH compliance list be updated?

Update it whenever ECHA changes the Candidate List or relevant restrictions, and whenever the product, supplier, material, formulation or factory changes. High-risk product categories should be reviewed more frequently than low-risk, stable materials.

Is a supplier declaration enough for REACH compliance?

Sometimes it is useful evidence, but it is not automatically enough. The declaration should identify the exact product scope, date, list version, threshold basis and responsible supplier. Higher-risk products may also need material declarations or targeted testing.

Can a product be REACH compliant if it contains an SVHC?

Yes, in some cases. The presence of an SVHC does not always mean the product is banned. It may trigger communication, notification or SCIP duties, and the product must still be checked against Annex XVII restrictions and any applicable customer or market requirements.