What is REACH regulation? The comprehensive impact of EU's Registration, Evaluation, Authorization and Restriction of Chemicals on manufacturing industry

 What is REACH regulation? The comprehensive impact of EU's Registration, Evaluation, Authorization and Restriction of Chemicals on manufacturing industry

The REACH regulation, officially known as the Registration, Evaluation, Authorisation and Restriction of Chemicals, is the world's most stringent chemical management regulation implemented by the European Union. It came into effect on June 1, 2007, and applies to almost all chemicals and their downstream products entering the EU market, covering the entire manufacturing sector from chemical raw materials, coatings, textiles, toys to electromechanical products.

The core logic of REACH is "no data, no market" and "liability inversion". This means that unless a company can prove the safety of its chemicals, they cannot be manufactured or sold in the EU; meanwhile, the responsibility for chemical safety has shifted from the government to the companies.

The following is a comprehensive guide to the impact of REACH regulation on the manufacturing industry and practical compliance steps:

📋 I. The Four Core Pillars of REACH Regulation

The REACH regulation manages chemicals throughout their entire lifecycle through four key aspects, directly affecting the supply chain and product compliance in the manufacturing industry:

Registration: Any chemical substance produced or imported in the EU in quantities exceeding 1 tonne per year must submit detailed registration files (including physicochemical properties, toxicological data, etc.) to the European Chemicals Agency (ECHA). Substances that have not completed registration will be prohibited from being placed on the market.

Evaluation: ECHA and EU member states will verify the registration files submitted by enterprises, assess whether the substances pose risks to human health or the environment, and may request enterprises to supplement data if necessary.

Authorisation: A strict licensing system is implemented for substances of very high concern (SVHC), such as carcinogens, mutagens, reproductive toxins, and persistent bioaccumulative substances. Companies must apply for authorisation to continue using these substances, and they need to demonstrate that the risks are manageable or that there are no safer alternatives available.

Restriction: This is the safety net of REACH. If the use of a certain substance poses an unacceptable risk, the EU will directly restrict or prohibit its specific use across the entire territory (for example, restricting lead, cadmium, phthalates, etc. in consumer products).

🏭 II. Comprehensive impact on manufacturing industry

The influence of the REACH regulation has long extended beyond the chemical industry, profoundly reshaping the supply chains of the global manufacturing industry:

Upgrading supply chain responsibility and transparency: Regulations require upstream and downstream enterprises to share chemical data. If a product contains SVHC substances and the concentration exceeds 0.1% (by weight), the supplier must provide downstream with safe use information; if the total annual export volume of such items to the EU exceeds 1 ton, they must also notify ECHA.

Increased compliance costs and entry barriers: Enterprises need to invest a significant amount of funds in chemical substance testing, data registration, and alternative material research and development. For example, the electronics industry needs to assess harmful substances in printed circuit boards, and toy exporters need to replace phthalate plasticizers.

Digital compliance requirements are becoming normalized: The European Union mandates that companies report product information containing Substances of Very High Concern (SVHC) through the Substance Control Information Portal (SCIP) database, promoting transparency in supply chain information. For complex manufacturing industries such as the automotive industry, where a complete vehicle involves thousands of components, compliance information collection and digital traceability (such as digital product passports) have become mandatory requirements.

Driving Green Innovation: Although REACH has increased compliance pressure in the short term, in the long run, it compels enterprises to eliminate high-risk substances and develop safer and eco-friendly alternatives. Compliance capability has become a "passport" and core competitiveness for enterprises to enter the high-end market.

📢 III. Latest Regulatory Developments and Trends in 2026

As of May 2026, the regulatory environment of the EU REACH Regulation has undergone the following key changes:

REACH 2.0 comprehensive revision plan shelved: In April 2026, the European Union officially announced the shelving of the nearly six-year-old REACH comprehensive revision plan (REACH 2.0). This means that enterprises temporarily do not need to deal with disruptive reforms such as "registration validity period" and "comprehensive registration of polymers". The regulatory focus will shift to simplifying and modernizing existing provisions, as well as strengthening border and market enforcement.

Accelerated restrictions on PFAS (permanent chemicals): Despite the shelving of a comprehensive revision, proposals to restrict **perfluorinated and polyfluoroalkyl substances (PFAS)** are moving forward at an accelerated pace. The core committee of ECHA has approved the risk assessment opinion, and formal restrictions are expected to be introduced in 2027. This will significantly impact the application of fluorine-containing materials (such as waterproof and oil-proof coatings, fluororubber, non-stick pans, etc.) in textiles, electronics, food contact materials, and other fields.

The SVHC list is continuously and dynamically updated: the list of substances of very high concern is dynamically expanding. As of February 2026, the SVHC list has been updated to include 253 items (with new additions such as n-hexane, Bisphenol AF, and its salts). Enterprises must keep track of the updates to the list in real-time.

💡 IV. Practical Suggestions for Manufacturing Enterprises

Conduct a comprehensive investigation of supply chain components: Review product formulas and BOM (Bill of Materials) tables to identify whether they contain substances on the SVHC (Substances of Very High Concern) list, especially if their concentration exceeds 0.1%. You can entrust a professional third-party testing agency to conduct SVHC screening.

Establish a dynamic compliance early warning mechanism: closely monitor updates to the SVHC list, progress on PFAS restrictions, and changes to authorization/restriction lists published on the ECHA official website, and adjust product formulas or processes in advance.

Implement information transmission and notification obligations: Ensure smooth information flow throughout the supply chain. If the product contains SVHC and meets the notification criteria, be sure to submit the SCIP database notification to ECHA on time.

Non-EU companies are required to designate a Unique Representative (OR): If a Chinese manufacturer directly exports chemicals (pure substances, mixtures, or intentionally released components in articles) to the EU, they must complete registration and compliance declaration through a **Unique Representative (Only Representative)** located within the EU.