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REACH compliance isn't optional—it’s your license to operate in the EU. If you're a manufacturer, importer, or supplier handling chemicals in the European market, you need more than just good intentions. You need a flawless system for staying compliant, audit-ready, and competitive.
Why a REACH Compliance Checklist Matters
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is one of the most comprehensive chemical regulations in the world. It affects every player in the supply chain—from substance manufacturers to downstream article assemblers.
A misstep doesn’t just mean fines. It could block your product from the EU market, damage your reputation, or disrupt your supply chain.
The 2025 REACH Compliance Checklist
1. Determine Your Role in the Supply Chain
Before anything else, know your position under REACH:
- Manufacturer: You produce substances in the EU.
- Importer: You bring substances, mixtures, or articles into the EU.
- Downstream User: You use substances professionally but don’t produce or import.
- Only Representative: You represent a non-EU manufacturer to fulfill EU obligations.
Action: Map out your supply chain roles for each product.
2. Check if Your Substance Needs Registration
REACH applies to substances ≥1 tonne/year. Check:
- Is it on the REACH Registration list?
- Has someone already registered it (pre-SIEF data)?
- Is your substance exempt (e.g., polymers, non-isolated intermediates)?
Action: Use ECHA’s registration portal or consult with your OR.
3. Compile Your Chemical Safety Report (CSR)
For substances ≥10 tonnes/year:
- Hazard assessment
- Exposure scenarios
- Risk characterization
Action: Generate or validate your CSR using standard templates (e.g., IUCLID).
4. Ensure Substance Traceability
Track every substance throughout your product lifecycle:
- CAS numbers
- Composition data
- Safety data sheets (SDS)
- Supplier declarations
Action: Maintain a digital trail via a PLM or FMD management tool.
5. Monitor Candidate List for SVHCs
REACH Candidate List updates every 6 months.
- Action: Screen your BOMs and supplier materials against the latest SVHC list.
- Bonus: Automate alerts with a compliance platform.
6. Disclose SVHCs in Articles (Article 33 Compliance)
If SVHCs > 0.1% w/w in any article:
- Notify customers
- Update SDS
- Submit data to SCIP (EU Waste Directive)
Action: Build automated workflows for SVHC screening and customer disclosures.
7. Check Annex XVII Restrictions
Restricted substances under Annex XVII cannot be manufactured, used, or marketed unless conditions are met.
Action: Verify restricted substances and apply usage thresholds.
8. Identify Annex XIV Authorisation Needs
If using Substances of Very High Concern (SVHCs):
- Review sunset dates
- Apply for authorisation before deadlines
Action: Begin the authorisation process at least 18 months in advance.
9. Maintain a Robust Document Trail
Documentation should include:
- Registration dossiers
- CSRs
- SDS and labels
- SVHC declarations
- Evidence of downstream communication
Action: Store for 10+ years post-placement on market.
10. Audit Your Supply Chain
Your compliance is only as strong as your weakest supplier.
- Action: Conduct yearly supplier audits and implement supplier scorecards.
- Tip: Use IPC-1752A, IEC 62474 standards for data uniformity.
Bonus: Digital Product Passport Readiness
REACH compliance today powers Digital Product Passports tomorrow. Preparing now ensures you're ready for upcoming Ecodesign requirements and EU Green Deal targets.
Want to Automate Your REACH Compliance?
Acquis helps you:
- Track REACH updates in real time
- Automate SVHC screening + supplier data validation
- Prepare SCIP dossiers, CSRs, and registration files
- Stay audit-ready across EU, UK, and global markets
