Supplier of Finished Goods

REACH registration applies to substances in their chemical sense at quantities of one tonne or more per year per legal entity. It is a duty for each substance manufacturer and each importer of substances either on their own, in mixtures, or if intentionally released from articles.

True articles, for example desk chairs and car parts, usually have a complex chemical composition. When an article is imported into the EU/EEA those inherent substances do not fall in scope of registration unless they are intentionally released; intentional release is usually taken to mean a secondary function of the object. An example would be the fragrance released from scented coat hangers.

Registration of substances intentionally released from articles follows the same format as the registration by a substance manufacturer or importer. The potential registrant must work with other manufacturers and importers of the same substance towards “one substance, one registration”. Every registrant must submit a dossier of information prepared in IUCLID and submitted to ECHA through REACH-IT.

For more information on the registration process and what you need to do please see our section on registration.

If an article contains more than 0.1% by weight of a substance on the Candidate List of substances of very high concern (SVHCs) the EU/EEA supplier must inform their customers and give them sufficient information to allow safe use of that article. The information must be given proactively, free of charge, to business customers; consumers are entitled to the same information by request within 45 days, again without charge. These duties are laid out in Article 33 of REACH.

For more information on Article 33 disclosure see our webpages on Substances in Articles and Supply Chain Communication.

EU importers and producers of articles containing more than 0.1% by weight of a Candidate List substance may need to notify ECHA if the amount of that substance reaches one tonne or more per year per legal entity. An information dossier must be submitted via REACH-IT, identifying the substance, its applications and the notifying company.

For more information on notification please see our webpage on Substances in Articles.

REACH can restrict the use and presence of substances in products which pose unacceptable risks to health or the environment. These restrictions are specified in Annex XVII to REACH.

Many restrictions place limits on the amount of a given substance in articles or parts of articles, often where those products are intended for the consumer. Articles not complying with a relevant restriction must not be placed on the EU/EEA market; companies in breach of Annex XVII restrictions may be subject to enforcement from the authorities in their Member State, and details of the breach may be disclosed on the European Commission’s RAPEX website.

For more information on restriction please see our dedicated webpage.