Your REACH Only Representative for non-EU substance manufacturers

REACH for mixtures, polymers and articles

REACH registers substances, but most exports to the EU are mixtures, polymers or finished articles. Here is how the obligations translate for each.

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Substances in mixtures count Polymers exempt, monomers not SVHC above 0.1% in articles Candidate List updated regularly

Mixtures

A mixture is not registered as such. Each substance in it is registered by the EU importer (or by an Only Representative appointed by the non-EU formulator) once the substance reaches 1 tonne per year. A non-EU company that formulates mixtures can appoint an OR for the substances in its mixtures, so its EU customers do not have to register them.

Polymers

Polymers are exempt from registration (Article 2(9)). However, the monomers and other substances that form the polymer must be registered if the polymer consists of 2% by weight or more of them in the form of monomeric units and chemically bound substances, and their total quantity reaches 1 tonne per year (Article 6(3)) - unless those monomers have already been registered by an actor up the supply chain.

Articles

Substances intended to be released from an article (for example a scented product) must be registered above 1 tonne per year (Article 7(1)).
Substances of Very High Concern (SVHC) on the Candidate List above 0.1% by weight in an article trigger a duty to give recipients enough information for safe use (Article 33), and to consumers on request within 45 days.
Notification to ECHA is required when an SVHC is present above 0.1% by weight and above 1 tonne per year per producer or importer (Article 7(2)).
SCIP database: EU suppliers of articles containing Candidate List SVHCs above 0.1% must also notify ECHA's SCIP database under the Waste Framework Directive.

Restrictions and authorisation

Registration is only one part of REACH. Annex XVII restricts certain substances in specific uses (for example PAHs in rubber and plastic parts), and substances on the Authorisation List (Annex XIV) cannot be used in the EU without an authorisation after their sunset date. Check both lists for every substance in your products.

Frequently asked questions

Do I need to register a mixture?

No. The substances in the mixture are registered individually, each from 1 tonne per year, by the EU importer or by an Only Representative of the non-EU formulator.

Are polymers exempt from REACH?

Polymers are exempt from registration, but their monomers and other reacted substances must be registered when they make up 2% or more of the polymer and reach 1 tonne per year, unless already registered up the supply chain.

What is the 0.1% SVHC rule?

If an article contains a Candidate List substance above 0.1% by weight, suppliers must provide information for safe use (Article 33). Notification to ECHA applies above 1 tonne per year per producer or importer (Article 7(2)).

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