Compliance

REACH checklist, row by row

Every REACH requirement on a product's checklist: when it applies, whose duty it is and how to record it.

Every row of a product's REACH checklist, in the order the checklist shows them, with the regulation's full wording, who does the work, when it applies and each way to record it. The checklist itself keeps only the row's name, its citation and the buttons to record it.

INFO: REACH names no document to hold for these duties. Each applies only if the article contains a Candidate List substance above 0.1% weight by weight. These duties belong to the supplier of the article, meaning any producer or importer of an article, distributor or other actor in the supply chain placing it on the market (Art. 3(33)); notifying the Agency under Article 7(2) belongs to the producer or importer of articles. An importer under REACH is a person established in the EU who is responsible for import (Art. 3(11)), and import counts as placing on the market (Art. 3(12)). So if your business is outside the EU, these duties sit with whoever places the article on the EU market, such as your EU importer, not with you directly.

Safe-use information to recipients of the article (Regulation (EC) No 1907/2006, Art. 33(1), for each product). Any supplier of an article containing a Candidate List substance in a concentration above 0.1% weight by weight must provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article — including, as a minimum, the name of that substance. A recipient of an article is an industrial or professional user, or a distributor; it does not include consumers (Art. 3(35)).

Whose work it is: This duty belongs to the supplier of the article: any producer or importer of an article, distributor or other actor in the supply chain placing it on the market (Art. 3(33)). An importer under REACH is established in the EU (Art. 3(11)), and import counts as placing on the market (Art. 3(12)) — so if your business is outside the EU, this duty sits with whoever places the article on the EU market, such as your EU importer, not with you directly.

Applies only when (Regulation (EC) No 1907/2006, Art. 33(1)): Does this article contain a Candidate List substance — a substance meeting the criteria in Article 57 of REACH and identified in accordance with Article 59(1) — in a concentration above 0.1% weight by weight?

How it is met:

  • Recipients are given the information — Confirm that recipients of this article (industrial or professional users, and distributors) are provided with sufficient information to allow its safe use, including at least the name of the substance.

Source: Regulation (EC) No 1907/2006, Art. 33(1) — Regulation (EC) No 1907/2006 (REACH), consolidated text CELEX:02006R1907-20250623 — EUR-Lex, converter generated_on 20250819. Articles 3, 7 and 33 read verbatim.. Read 2026-09-14.

Safe-use information to consumers on request (within 45 days) (Regulation (EC) No 1907/2006, Art. 33(2), for each product). On request by a consumer, any supplier of an article containing a Candidate List substance in a concentration above 0.1% weight by weight must provide the consumer with sufficient information, available to the supplier, to allow safe use of the article — including, as a minimum, the name of that substance. The information must be provided free of charge, within 45 days of receipt of the request.

Whose work it is: This duty belongs to the supplier of the article: any producer or importer of an article, distributor or other actor in the supply chain placing it on the market (Art. 3(33)). An importer under REACH is established in the EU (Art. 3(11)), and import counts as placing on the market (Art. 3(12)) — so if your business is outside the EU, this duty sits with whoever places the article on the EU market, such as your EU importer, not with you directly.

Applies only when (Regulation (EC) No 1907/2006, Art. 33(2)): Does this article contain a Candidate List substance — a substance meeting the criteria in Article 57 of REACH and identified in accordance with Article 59(1) — in a concentration above 0.1% weight by weight?

How it is met:

  • Consumer requests are answered — Confirm that a consumer who asks is provided with this information — including at least the name of the substance — free of charge, within 45 days of receipt of the request.

Source: Regulation (EC) No 1907/2006, Art. 33(2) — Regulation (EC) No 1907/2006 (REACH), consolidated text CELEX:02006R1907-20250623 — EUR-Lex, converter generated_on 20250819. Articles 3, 7 and 33 read verbatim.. Read 2026-09-14.

Notification to the Agency (ECHA) (Regulation (EC) No 1907/2006, Art. 7(2), for each product). A producer or importer of articles must notify the Agency if a Candidate List substance is present in those articles both above a concentration of 0.1% weight by weight AND in quantities totalling over one tonne per producer or importer per year. The notification includes the producer's or importer's identity and contact details, any registration number available, the substance's identity and classification, a brief description of its use in the article and of the article's uses, and the tonnage range (Art. 7(4)). It does not apply to a substance already registered for that use (Art. 7(6)), and it applies six months after the substance is identified in accordance with Article 59(1) (Art. 7(7)).

Whose work it is: This duty belongs to the producer or importer of the articles. An importer under REACH is a person established in the EU who is responsible for import (Art. 3(11)) — so if your business is outside the EU, this duty does not sit with you directly.

Applies only when (Regulation (EC) No 1907/2006, Art. 7(2)): Is that substance present in the producer's or importer's articles in quantities totalling over one tonne per year? The threshold is counted per producer or importer.

Ways to meet it (any one):

  • The Agency has been notified — Confirm the Agency has been notified of this substance in these articles, with the information listed in Article 7(4).
  • Exposure can be excluded (Art. 7(3)) — Confirm the producer or importer can exclude exposure to humans or the environment during normal or reasonably foreseeable conditions of use, including disposal.
    • Also record: Appropriate instructions are supplied to the recipient of the article (Regulation (EC) No 1907/2006, Art. 7(3))
  • Already registered for that use (Art. 7(6)) — Confirm the substance has already been registered for that use.

Source: Regulation (EC) No 1907/2006, Art. 7(2) — Regulation (EC) No 1907/2006 (REACH), consolidated text CELEX:02006R1907-20250623 — EUR-Lex, converter generated_on 20250819. Articles 3, 7 and 33 read verbatim.. Read 2026-09-14.

Not required, but worth holding

  • SVHC Declaration (REACH Article 33) — Not required by REACH. A supplier's declaration of the Candidate List substances in an article, and their concentrations, is one way to answer whether these duties apply.

INFO: This lists what the checklist records. It is not legal advice, and a row recorded in Aleph is not a finding that the product complies.

Related articles