What Should a REACH Compliance Statement Include for EU Imports?

Why Does a REACH Compliance Statement Matter for Importers?

A REACH compliance statement is not just a supplier letter kept in a file. For importers, distributors, and private-label buyers, it is a short record showing how a product, material, or component was checked against EU chemical rules. If you buy finished goods outside Europe and sell them into the EU market, this document helps your team check supplier claims before the shipment leaves the factory. For broader trade document support, visit the Compliance section.

REACH, formally Regulation (EC) No 1907/2006, is the European Union’s main chemical regulation. The European Commission describes it as the key EU law for protecting human health and the environment from chemical risks. In daily sourcing work, that can mean plastics, textiles, coatings, adhesives, packaging, electronics, tools, promotional gifts, and many small parts that buyers may not check until customs or a customer asks for documents.

It Turns Supplier Promises into Written Evidence

A verbal “yes, compliant” from a factory does not give much cover. A written statement gives you a date, named products, stated standards, and a responsible signer. It does not replace testing or legal review, but it gives your file a place to start. If a retailer, marketplace, or EU customer asks for REACH documents, you can send something more useful than an old email thread.

It Helps You Spot Risk Before Shipping

The best time to find a chemical compliance issue is before production, not when the goods are already sitting in a port warehouse. A useful statement should show whether the supplier checked the current SVHC Candidate List, Annex XVII restrictions, and any product-specific chemical limits. Soft PVC toy parts, coated metal accessories, artificial leather, printed textiles, and rubber grips often need a closer look. These are common items, but chemical risk can sit in additives, dyes, flame retardants, and surface treatments.

It Reduces Confusion Across the Supply Chain

Many export orders pass through trading companies, factories, subcontractors, packaging vendors, and freight teams. Small changes can happen along the way: a black cable becomes grey, a coating supplier changes, or a recycled plastic batch is used in production. A dated statement gives everyone the same reference point. When the product specification changes, the statement should be checked again, because this simple step can avoid a lot of slow and costly follow-up later.

What Should a REACH Compliance Statement Include?

A good statement should be easy for a buyer to read in a few minutes and detailed enough for a compliance file. It should not be a vague certificate saying “all products meet EU standards” without product names. That kind of document may look convenient, but it is weak when a customer asks which material, which list date, and which restriction was checked.

Supplier and Product Identification

Start with the supplier’s legal name, address, contact person, and statement date. Then list the product name, model number, SKU, material description, and purchase order or drawing number if available. If the statement covers several products, use an attachment table so the scope is clear. Be careful with broad family claims, because a stainless-steel bracket and a painted bracket may need different chemical checks even if both appear in the same catalog section.

REACH Scope and Checked Requirements

The statement should name REACH Regulation (EC) No 1907/2006 and say which parts were checked. For finished articles, the main items often include SVHC Candidate List screening under Article 33, Annex XVII restrictions, and SCIP duties if applicable. For substances or mixtures, registration status, safety data sheets, classification, and intended use may also matter. The European Commission states that substances above 1 tonne per year per company must be registered with ECHA, so import volume is not a small detail for chemical products.

Clear Declaration, Date, and Signature

The declaration should say whether the product contains any Candidate List SVHC above 0.1% weight by weight, based on the latest review date used by the supplier. If none are present above that level, state it in plain wording. If one is present, name the substance, concentration range, article where it appears, safe-use information, and any SCIP notification reference held by the EU supplier. The statement should end with an authorized signature, job title, company stamp if used locally, and a review trigger such as “valid until the next Candidate List update or product change.”

Which REACH Duties Should Your Statement Cover?

A statement is useful when it follows the actual legal duties. REACH duties are not the same for every product. A bottle of adhesive, a plastic chair, a phone cable, and a machined part do not need the same paperwork. The supplier should state the basis for the claim, not only the final result.

SVHC Candidate List Screening at 0.1 Percent

ECHA explains that Candidate List substances in articles can trigger legal duties for producers, importers, and suppliers. The main threshold for articles is usually 0.1% weight by weight. If a supplied article contains a Candidate List substance above that level, the supplier must give professional recipients enough information for safe use, including at least the substance name. The European Commission also notes that consumers have the right to ask about SVHCs in articles, and companies must reply within 45 days.

Annex XVII Restrictions for Product-Specific Limits

SVHC screening on its own is not enough. Annex XVII restrictions can ban or limit substances in certain uses, often with exact product categories and concentration limits. Common cases include phthalates in certain plasticized materials, nickel release from items in prolonged skin contact, azo dyes in textiles and leather, and lead in some consumer articles. Your statement should say whether Annex XVII was checked for the real product type, because a generic SVHC-free letter does not answer that point.

SCIP Notification When SVHCs Are Present

The SCIP database applies to articles placed on the EU market that contain Candidate List SVHCs above 0.1% weight by weight. ECHA states that the notification duty has applied since 5 January 2021. If your product triggers SCIP, the statement should say so clearly. It should identify the affected article, the SVHC, safe-use instructions, and the available SCIP number or confirmation from the EU duty holder. In a complex product, the metal housing may be fine, while one small plastic washer inside can still create a reporting duty.

How Can You Check Whether the Statement Is Reliable?

Not every document called a “REACH declaration” is worth relying on. Some templates are reused for years without checking the latest Candidate List. Others name the wrong regulation, miss restricted substances, or cover raw materials only but not the finished product. A simple review habit helps you sort useful documents from papers that only look complete.

Match the Statement to the Current Product

Compare the statement with your purchase order, drawing, bill of materials, and product photos. The model number should match, and the color, coating, cable type, packaging, and accessories should match as well. If the statement says “ABS housing” but the product uses soft PVC overmolding, ask the supplier to check again. This may feel picky, but many real compliance problems start with a small material mismatch that nobody treated as important.

Check the Candidate List Review Date

The Candidate List changes over time. ECHA added two hazardous chemicals to the Candidate List on 4 February 2026, bringing it to 253 entries according to ECHA’s public news at that time. A statement issued in 2023 may still help as background, but it should not be treated as current proof. Ask suppliers to state the Candidate List version or review date, and if they cannot do that, request an updated statement before shipment.

Ask for Test Reports When Risk Is Higher

A supplier declaration is not the same as a lab report. For low-risk metal parts with steady material control, a declaration plus material specification may be enough for many buyers. For plasticized materials, children’s products, skin-contact items, electronics cables, synthetic leather, paints, adhesives, and mixed recycled material, ask for test reports from a qualified lab when possible. The European Commission’s Safety Gate 2025 report recorded 4,671 dangerous product alerts, and chemical risk was the most notified risk category at 53%. That public data is a good reminder that paper-only checks can be too light for higher-risk goods. See also: Customs.

What Mistakes Make a REACH Statement Weak?

Most weak statements fail for basic reasons. They are too broad, too old, or not linked to the real product. The fix is not better wording. The fix is tighter scope, clearer support, and regular updates.

Using One Generic Letter for Every Product

A single letter for every item in a supplier catalog may look efficient, but it rarely works in a detailed customer review. REACH status depends on materials, use, concentration, and product category. A supplier that sells silicone kitchen tools, painted metal parts, PVC mats, and printed packaging should not use one sentence for all of them. Ask for a product-specific or product-family statement with clear limits, so the claim matches the goods you are buying.

Ignoring Mixtures, Coatings, and Accessories

Finished goods are often reviewed as articles, but coatings, inks, glues, batteries, cleaning fluids, and spare chemical packs can add extra duties. Safety data sheets may be needed for substances or mixtures. If your shipment includes a liquid, paste, powder, aerosol, adhesive, or chemical refill, do not rely on an article-only statement. The paperwork should match the shipped goods, including small accessories, because customs staff and retailer compliance teams do notice these details.

Forgetting UK REACH and Market Differences

EU REACH and UK REACH are separate systems. If you sell into Great Britain, do not assume that an EU statement automatically covers UK duties. The UK Health and Safety Executive also uses a Candidate List process and similar 0.1% article communication duties, but the lists and administrative steps can differ. If your buyer serves both EU and UK markets, ask for a statement that says exactly which market it covers.

How Should You Build a Practical REACH Document File?

A good document file should be easy to use when a customer asks questions. It should help you trace supplier claims, answer quickly, and update records when ECHA changes a list. You do not need a hundred-page folder for every order, but you do need a clean trail that your team can follow.

Keep a Core File for Each Product

For each SKU, keep the REACH compliance statement, bill of materials, material declarations, test reports, safety data sheets where relevant, product photos, supplier contacts, and the Candidate List review date. Store old versions too, not only the latest file. If a supplier changes a coating in June, you need to know which orders used the old coating and which used the new one. A simple spreadsheet can work well enough if someone keeps it updated.

Set Review Triggers Before Problems Appear

Review the statement when the Candidate List changes, when the product design changes, when a material supplier changes, when a customer raises a new requirement, or when you enter a new market. Also check it again after a failed test, recall notice, or Safety Gate alert involving a similar product type. This is not paperwork for its own sake. It costs less than arguing about responsibility after a container has arrived.

Use a Simple Supplier Request Template

Your supplier request should ask for product identification, REACH scope, Candidate List date, SVHC status, Annex XVII review, SCIP status, test reports if available, SDS where relevant, and signer details. Keep the wording direct, because suppliers usually respond better to a clear checklist than a long legal paragraph. If the product is high risk, ask for supporting reports before mass production. Waiting until final inspection is a bad habit, and many buyers learn that lesson only after a shipment is already late.

FAQ

Q1: Is a REACH Compliance Statement Legally Required? A: REACH creates legal duties, but the document called a REACH compliance statement is usually a commercial declaration used to show how those duties were checked. Customers, marketplaces, and importers often ask for it as part of their compliance file.

Q2: Does a Supplier Declaration Replace Lab Testing? A: No. A declaration records the supplier’s claim. Lab testing gives technical evidence for selected substances and materials. Higher-risk products often need both.

Q3: How Often Should a Statement Be Updated? A: Update it when the Candidate List changes, when the product or material changes, or when a buyer asks for a newer review. Many importers request at least an annual refresh for active SKUs.

Q4: What If an SVHC Is Above 0.1 Percent? A: The statement should name the substance, identify the affected article, give safe-use information, and address Article 33 and SCIP duties if the product is placed on the EU market.

Q5: Can One Statement Cover Many Products? A: Yes, but only when the scope is clear. Use a product table with model numbers, materials, and covered versions. Avoid vague catalog-wide claims that do not match real materials.