Understanding Who Must Comply With EU REACH Regulation

A Simple Guide for Beginners

EU REACH does not apply only to chemical factories. It affects many types of businesses that make, import, sell, or use chemicals in the European Union (EU).

Whether REACH applies to your company depends on:

• What activities your company performs

• What products you place on the EU market

• How much of a chemical you handle each year

This guide explains who REACH covers, what actions trigger obligations, and how the rules apply to substances, mixtures, and articles.

Who Does REACH Apply To?

REACH applies to companies operating in:

• European Union (EU) countries

• European Economic Area (EEA) countries (Norway, Iceland, Liechtenstein)

In general, REACH obligations start when a company manufactures or imports 1 tonne or more per year of a chemical substance.

What Activities Can Trigger REACH Obligations?

Your company may fall under REACH if you do any of the following:

• Manufacture chemical substances in the EU/EEA

• Import chemical substances into the EU/EEA

• Prepare mixtures (such as paints, coatings, detergents)

• Produce or import articles that contain chemical substances

• Recover chemical substances from waste

• Use chemicals in industrial or professional activities

It does not matter if the chemical is sold, used internally, or present inside a product — REACH can still apply.

Different Roles Under REACH

Your responsibilities depend on your role in the supply chain.

Manufacturers

Companies that make chemical substances in the EU/EEA must register them if the quantity reaches 1 tonne or more per year.

Importers

Companies that bring substances, mixtures, or articles from outside the EU/EEA into the EU are responsible for REACH — not the foreign supplier.

Downstream Users

These are companies that use chemicals in their operations (formulators, industrial users, professional users).
They must:

• Ensure their uses are covered by a REACH registration

• Follow safety instructions and risk management measures

Distributors

Distributors store and sell chemicals but usually do not register substances.
However, they must pass on safety information through the supply chain.

Non-EU Companies (Only Representative)

Non-EU manufacturers cannot register directly. They may appoint an Only Representative (OR) based in the EU to handle REACH obligations.

Does REACH Apply to Articles?

Yes. REACH also applies to articles, such as:

• Clothing and textiles

• Furniture

• Electronics

• Car parts

• Toys and consumer products

But the rules for articles are different and depend on certain conditions.

When Must Substances in Articles Be Registered?

Registration is required only if both conditions are met:

1. The substance is intended to be released during normal use, and

2. The total amount of that substance exceeds 1 tonne per year

Examples:

• Ink released from a pen

• Fragrance released from scented products

If the substance is not meant to be released, registration is usually not needed — but other duties may still apply.

REACH Duties for Articles Without Intended Release

Even if registration is not required, REACH still applies if:

• The article contains a Substance of Very High Concern (SVHC) above 0.1%, and

• The article is placed on the EU market

In this case, companies must:

• Inform customers about SVHCs (Article 33 duty)

• Submit information to the SCIP database

Does REACH Apply to Recovered Substances?

Yes.
If you recover a chemical from waste and place it on the market in quantities of 1 tonne or more per year, REACH may apply unless a specific exemption exists.

Are There Any Exemptions?

Some substances are partly or fully exempt, such as:

• Radioactive substances

• Waste

• Substances used in food or animal feed

• Certain naturally occurring substances

However, exemptions are limited and must be checked carefully.

Who Is Responsible for Registration?

Responsibility depends on supply chain position:

• EU manufacturers → register what they produce

• EU importers → register what they import

• Non-EU companies → use EU importer or Only Representative

• Article producers/importers → responsible for article-related duties

Each legal entity is responsible for its own compliance.

Why Understanding This Is So Important

Many REACH problems happen because companies misunderstand whether REACH applies to them.

You must clearly know:

• Your role (manufacturer, importer, downstream user)

• Your product type (substance, mixture, article)

• Your yearly quantity

This is the foundation of REACH compliance.

Final Message

REACH affects many industries — not just chemical manufacturers.
If your company makes, imports, or uses chemicals or products in the EU, REACH likely applies.

Understanding your responsibilities is the first and most important step. Once this is clear, you can move forward with registration, risk assessment, and supply chain communication confidently.