REACH
REACH stands for Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals. REACH came into force across the European Union in 2006 and a version of it was retained in UK law following the UK’s exit from the EU in 2020.
The Regulation aims to ensure a high level of protection of human health and the environment. It lays down a comprehensive framework of requirements for the manufacture, import, supply and use of chemicals.
REACH is extremely broad in its application. It applies to almost all chemical substances, not just those used in industrial processes or by professionals at work, but also to products used in everyday life. It places duties on those who manufacture, import, supply or use chemicals, whether as:
a substance on its own
in mixtures (e.g. cleaning products, paints, adhesives, detergents etc)
in articles (e.g. clothing, furniture, electrical appliances, packaging etc)
In this way, REACH applies to most businesses. Even businesses that wouldn’t normally think of themselves as being involved with chemicals can be affected by REACH. Most businesses rely on chemicals in some way, even if they do not realise it.
What is REACH?
The requirements REACH places on businesses depend on what those businesses do. REACH places duties on “actors in the supply chain”, such as manufacturers, importers, suppliers and downstream users of chemicals.
A good way of illustrating how these duties apply is to consider a simple supply chain. Identifying where you lie in this supply chain establishes what duties you will have under REACH.
Manufacturers and importers: Those at the top of the supply chain will be subject to registration related duties under REACH. Notification duties may also be placed on producers and importers of articles. Businesses outside the EU or UK can choose to appoint an ‘only representative’ (OR), in which case the OR will take on the duties otherwise placed on importers.
Suppliers: Those in the middle of the supply chain are subject to supply related duties under REACH. These include distributors or retailers although the duties apply to any business that places substances, mixtures or articles on the market, which could include manufacturers, importers and downstream users. They must pass on safety, health and environmental information to their customers, typically via safety data sheets (SDS) for substances and mixtures, or by communicating information on ‘substances of very high concern’ (SVHCs) in articles.
Downstream users: Businesses using chemicals are referred to as ‘downstream users’ and are required to use those chemicals safely. They are expected to apply the risk management information provided by their suppliers to control risks to people and the environment and to take action if their uses fall ‘outside’ the scope of registrations.
It is often the case that a business might have several, or possibly all, of these roles depending on their activities. For instance, a business might import chemicals (attracting registration duties) in order to make articles (considered to be a downstream use of chemicals) which they then place on the market (supply).
As well as the general areas described above, REACH also imposes other types of duties on industry. Registered substances are subject to evaluation, which refers to various different processes by which the accuracy and quality of information submitted can be verified. REACH also places restrictions on certain very dangerous substances on their own, in mixtures or in articles and, for other substances of very high concern, use-specific authorisation is required.
Who has duties under REACH?
How does REACH interact with other legislation?
REACH does not operate in isolation. It sits alongside, and interacts closely with, a wide range of other regulatory regimes governing the use of chemicals, including occupational health and safety legislation, environmental protection law and sector specific product regimes. Through its registration requirements, REACH places responsibility on manufacturers and importers to identify hazards, assess risks and define appropriate risk management measures, with this information communicated down the supply chain through safety data sheets (SDS). These outputs are then relied upon by downstream users to meet their own regulatory duties, for example in workplace risk assessments under COSHH. In practice, REACH functions as an upstream framework that informs and underpins compliance across multiple regimes, rather than replacing them.
Following the UK’s exit from the EU, REACH has been retained in Great Britain as a separate regime, known as UK REACH. While the core structure and principles remain largely the same, UK REACH and EU REACH now operate independently, with separate legal frameworks, regulatory authorities and processes. This means that businesses placing substances on both the GB and EU markets need to comply with both regimes, including meeting separate registration, authorisation and restriction requirements. The two regimes have already diverged significantly, creating additional complexity in areas such as regulatory controls, substance prioritisation and data management.
What about Brexit?
REACH is one of the most significant and far reaching pieces of chemicals legislation globally, with direct implications for market access, supply chain continuity and regulatory risk. It requires companies to understand the hazards and risks of the substances they manufacture, import, supply or use, and to demonstrate that those risks can be adequately controlled. Failure to meet these obligations jeopardises market access, reflecting REACH’s core principle of “no data, no market”. In practice, REACH compliance is not just a set of legal requirements but a fundamental business enabler, and getting it right is critical to maintaining access to markets, managing regulatory exposure and supporting the safe and sustainable use of chemicals.
The significance of REACH
Follow the links below to find consolidated copies of the EU and UK versions of REACH, as well as guidance published by ECHA and HSE:
Law and guidance
Find out how we help businesses understand, implement and demonstrate compliance with EU REACH and UK REACH, with a focus on practical, proportionate and defensible solutions.
Our services
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REACH compliance assessments, audits and gap analysis, including site visits, review of supporting documentation and due diligence checks, with clear reporting of findings and priorities for action.
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Inspection and enforcement preparedness, including support in preparing for regulatory inspections and investigations, help with follow-up, and strengthening the evidence base that underpins compliance.
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Chemical inventory management and obligation mapping, to identify which substances, mixtures and articles create duties, and who holds which responsibilities across complex supply chains.
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Registration strategy and ongoing compliance, including role clarification (manufacturer, importer, supplier, downstream user, Only Representative), dossier lifecycle planning and responses to evaluation or information requests.
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Authorisation support, including strategic advice and hands-on preparation of applications for authorisation, drawing on extensive practical experience of authorisation processes.
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Restriction compliance and implementation, including assessment of applicability, supply chain implications, operational controls, due diligence demonstration, and documentation to demonstrate compliance.
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Downstream user compliance, including interpretation of SDS and exposure scenario information and practical support to identify and apply appropriate risk management measures, aligned with COSHH and DSEAR where relevant.
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Product formulation and composition review, including assessing how formulation choices affect REACH duties, downstream implications and supply chain communications.
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Brexit support and managing divergence, including practical advice for organisations supplying both GB and EU markets, and for supply chains affected by changing roles and responsibilities.
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Supply chain and supplier assurance, including assessing supplier readiness and compliance performance, and supporting supply chain communications where needed.
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Advocacy and strategic engagement, including regulatory strategy, participation in consultations, and support with positions that are evidence-based and enforceable in practice.
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Compliance management systems, including developing and strengthening the governance, procedures, training and records that underpin day-to-day compliance and make it sustainable.
