The European Chemicals Agency (ECHA) has published the results of a European inspection project focusing on imported sustances, mixtures and articles. The key message is clear: imports remain a critical point of non-compliance under REACH, particularly when it comes to substances in mixtures and consumer products.
What the inspections found (and why it matters)
As part of the project (Forum REF-12), authorities carried out 2,603 inspections in 29 countries, in cooperation with customs and national enforcement authorities.
Important: The controls were targeted inspections, focusing on products where non-compliance was expected. A large proportion of the checks concerned imported jewellery, as well as toys, textiles and footwear. Therefore, the results do not represent a “global” non-compliance rate for all imports, but they clearly show where authorities are focusing their enforcement efforts.
Key findings include:
- REACH registration:
In checks on substances present in mixtures, approximately 1 in 3 (32%) lacked the required REACH registration.
For substances imported as such, registration was missing in 7% of cases
- REACH restrictions (Annex XVII): In more than 1,300 checks on mixtures and consumer products, 16% were found to contain restricted hazardous substances above the permitted limits.
- REACH authorisation (Annex XIV): Out of 21 cases reviewed, situations involving missing or expired authorisations were identified in 4 cases.
The root of the problem: Importing is not enough, you must know what you are placing on the market
One of the issues that most concerns authorities is that, in many cases, importers were not fully aware of their obligations and, in some situations, did not know exactly which substances they were placing on the market.
This is critical under REACH, because the importer (unless an Only Representative (OR) covers the import) is responsible for:
- Ensuring REACH registration of substances
- Verifying compliance with applicable restrictions, and
- Confirming compliance with authorisation obligations, where applicable.
What companies can do: From reaction to prevention
For many companies, the greatest risk lies in not having a realistic picture of their REACH situation and relying on incomplete or unverified information from the supply chain.
Good practices to adopt before importing (or ahead of an inspection) include:
- Confirming the role in the supply chain (Importer or Downstream User, depending on the existence of an OR).
- Identifying substances in mixtures (real and traceable composition).
- Verifying REACH registration, where applicable, and the scope of the OR coverage, if any.
- Reviewing applicable restrictions (Annex XVII) by use, product category, concentration, etc
- Checking whether substances subject to authorisation (Annex XIV) are present and confirming their status.
- Having robust evidence available (e.g. analytical reports, technical documentation and traceability) to respond effectively to inspections.
How ServiREACH can help: A REACH Audit to get the “Full picture” and a realistic action plan
At ServiREACH, we offer a REACH Audit service, designed to help companies understand their regulatory situation, identify risks, and define an action plan to correct deviations and prepare for a potential REACH inspection.
What our REACH Audit includes
- Preliminary situation assessment.
- On-site visit, interviews with key personnel, and review of data, documentation and compliance evidence.
- Final report identifying risks, recommendations and a tailored action plan.
- Closing meeting to clarify findings and coordinate next steps.
What you gain from this Audit
- A comprehensive, documented overview of the company’s REACH compliance status.
- Identification of non-compliance before it is detected by inspectors or customers, reducing risks to market access and company reputation.
- Detection of areas where interpretation risks exist or where documentation needs strengthening.
- Clear recommendations to reduce uncertainty, reinforce evidence and improve traceability.
- Practical preparation for future inspections, enabling a structured, well-argued response and minimising disruptions, urgent corrective actions or potential penalties.
Do you import substances, mixtures or products into the EU/EEA?
If your company imports products and wants to anticipate inspections or avoid commercial blockages, a REACH Audit is one of the most effective ways to turn potential non-compliance into a controlled and predictable process.
If you are interested, we can help you assess the scope and adapt the audit to your specific situation (type of product, distribution channels, countries, volumes and supply chain).
