Your supplier sends you a PDF titled "REACH Certificate." It has a stamp, a reference number, and the words conforms to Regulation (EC) No 1907/2006. You file it, feel briefly reassured, and move on.
I did this for longer than I'd like to admit.
Here's the problem: there is no such thing as a REACH certificate. No authority issues one. What your supplier sent you is a test report, a self-declaration, or occasionally a document that means nothing at all — and the difference matters, because if the product turns out to contain a restricted substance, the person the authorities come to is you.
REACH sounds like something for chemical manufacturers, and most of it is. But if you import finished products into the EU, three specific parts of it land on your desk. This article is about those three, and about what they actually cost — which is less than you think, and mostly not money.
What REACH is, in one paragraph
REACH — Registration, Evaluation, Authorisation and Restriction of Chemicals, Regulation (EC) No 1907/2006 — is the EU's framework for controlling chemical substances. It's enormous, and the vast majority of it governs companies that manufacture or import chemicals in bulk.
You're not doing that. You're importing a finished article: a bottle, a garment, a phone case, a silicone product. The technical term matters here, because REACH treats substances, mixtures and articles differently, and as an importer of articles you sit in the lightest category.
Lightest is not the same as exempt.
The three things that are actually yours
1. Restricted substances — the hard limits
REACH Annex XVII lists substances that are restricted or banned in specific applications. If your product exceeds a limit, it cannot legally be sold. There's no paperwork route around it — the product is simply non-compliant.
The one most likely to catch a first-time importer is phthalates. Annex XVII restricts DEHP, DBP, BBP and DIBP to 0.1% by weight in plasticised material, with a further restriction covering DINP, DIDP and DNOP in toys and childcare articles that can be mouthed.
That matters if your product involves soft plastic, PVC, synthetic leather, coated fabric, flexible tubing, or anything with a rubbery hand-feel. Phthalates are plasticisers — they're what makes hard plastic soft. A factory switching to a cheaper plasticiser mid-production is a real and unremarkable event.
Other entries worth knowing about, depending on your category:
| Substance / group | Where it hides | Annex XVII limit |
|---|---|---|
| Phthalates (DEHP, DBP, BBP, DIBP) | Soft plastics, PVC, synthetic leather, coatings | 0.1% by weight in plasticised material |
| Heavy metals (lead, cadmium, mercury, hexavalent chromium) | Pigments, coatings, metal alloys | Varies by application; some outright banned |
| Azo dyes (certain aromatic amines) | Textiles, leather | 30 mg/kg |
| Nickel release | Metal items with prolonged skin contact | 0.5 μg/cm²/week |
| Formaldehyde | Textiles, resins, pressed wood | Varies by product type |
What you do about it: identify which Annex XVII entries could plausibly apply to your materials before you order, and get the specific formulation tested. Not the material category — the formulation.
2. The Candidate List and the SVHC threshold
Separately from outright restrictions, ECHA maintains a Candidate List of Substances of Very High Concern (SVHCs). These aren't banned in articles, but their presence triggers obligations.
The trigger is 0.1% by weight. And here's the detail almost everyone gets wrong:
The 0.1% threshold applies per component, not to the whole finished product.
So if your product is a 500 g device and one 5 g gasket inside it contains an SVHC at 2%, you are over the threshold — even though the substance is a rounding error against the total weight. Diluting across the whole product is not how the maths works.
Two obligations follow if you're over:
- Supply-chain communication. You must pass sufficient information down the chain to allow safe use.
- Consumer requests. If a consumer asks whether your product contains a Candidate List substance above 0.1%, you must respond with safe-use information within 45 days, free of charge.
The Candidate List is updated roughly twice a year and now runs to 253 entries as of February 2026 (n-hexane and Bisphenol AF were the most recent additions). A product that was clear when you launched can drift out of compliance without anything about it changing.
Check the current SVHC Candidate List on ECHA →
3. SCIP notification — the one nobody mentions
This is the obligation I see missed most often, partly because it doesn't come from REACH itself.
Since 5 January 2021, under the Waste Framework Directive, suppliers of articles containing Candidate List SVHCs above 0.1% w/w must notify those articles to ECHA's SCIP database. There is no tonnage threshold — one unit counts.
Who this applies to: EU producers, importers, assemblers and distributors. Who it exempts: retailers supplying directly and exclusively to consumers.
Read that exemption carefully, because it's narrower than it sounds. Sell only to consumers from your own shop and you're likely outside it. Sell to a stockist, a wholesaler, or through a channel that isn't exclusively consumer-facing, and you're a supplier in the chain — and the notification is yours.
Learn about SCIP notification →
The "REACH certificate" trap
Back to that PDF.
When a supplier sends you REACH documentation, it's one of three things:
A test report from an accredited laboratory. Useful — if the scope matches your product. Check which substances were screened, which exact model and material, the test date, and the lab's accreditation under the ILAC/IAF mutual recognition arrangements.
A self-declaration from the factory. The factory asserting compliance. Worth having on file, worth exactly as much as your trust in that factory.
A document about something adjacent. A report for a different product line. A screening for four phthalates presented as general REACH clearance. A certificate for the raw material rather than the finished part. I've seen all three.
The check that takes one minute: open the report and find the list of substances actually tested. If your product is soft plastic and the report screens for heavy metals but not phthalates, it does not tell you what you need to know — regardless of what the covering email says.
What happened to me
I worked on silicone products in body contact. The factory's documentation said "silicone," which is a material family, not a specification. It told me nothing about whether that particular formulation, from that particular batch, met the chemical requirements for a product designed to touch skin.
The certificate was real. It was also close to useless for the question I needed answered.
What resolved it wasn't a better certificate from the supplier. It was commissioning the test myself — which brings us to cost.
What REACH compliance actually costs
Here's where expectations tend to be wrong in both directions.
The obligations themselves cost nothing
Identifying which Annex XVII entries apply: free, public information. Checking the Candidate List: free, on ECHA's website. Responding to a consumer request within 45 days: your time. SCIP notification: free to submit.
None of this requires a consultant on retainer.
Testing costs money — but far less than people assume
If you need to verify a formulation, someone has to run a lab test. Two routes:
Commercial accredited laboratories — SGS, Bureau Veritas, Intertek, TÜV. Straightforward, quotable, more expensive.
National public health institutes. This is the route most people don't know exists. I used the Czech National Institute of Public Health (SZÚ) — a contributory organisation of the Czech Ministry of Health, running Testing Laboratory No. 1206, accredited by the Czech Accreditation Institute. It issued a certificate in my company's name naming the tests performed and the result.
It came to roughly 1,000 CZK per product — about €40 — with a one-month turnaround.
Two caveats on that number. It was my negotiated price for a defined material-safety scope, and there is no published tariff — they quote each testing batch individually. Which has a useful consequence: because pricing is per batch, the per-product cost drops when you test several products or variants together. Launching a small range? Test the range, not one item at a time.
Most EU member states have an equivalent national institute. Whether each takes commercial work varies by country — worth one email to find out.
The cost that actually hurts
Not euros. Weeks.
A month of lab turnaround sitting between sample approval and production is a month you're not selling. Discover a required test in month five and you have inventory paid for, marketing scheduled, and nothing you can legally ship.
Put testing on the timeline next to tooling and samples. That's the whole trick.
A short checklist you can actually use
- List your materials. Every component, by material and by weight. You cannot assess a product you haven't broken down.
- Identify plausible Annex XVII entries for those materials. Soft plastic → phthalates. Textiles → azo dyes. Metal in skin contact → nickel release. Coatings and pigments → heavy metals.
- Ask the supplier for test reports covering your exact model and material, dated within twelve months, from an accredited lab.
- Read the scope. Which substances, which model, which date, which lab. If the scope doesn't cover your question, the report is decoration.
- Verify anything that matters by commissioning your own test — accredited lab or national institute. Get the certificate in your company's name, not the factory's, so it's usable in your marketing and portable if you change supplier.
- Check whether any component exceeds 0.1% SVHC. If yes: supply-chain communication, the 45-day consumer response, and SCIP notification.
- Re-check the Candidate List at least annually. It grows.
REACH Self-Check Checklist for First-Time Importers
The 7-step process in one printable page — what to check, in what order, and the red flags that mean stop. PDF, no email required.
Download checklist →Or join the course waitlist for the full compliance module with templates.
FAQ
Does REACH apply to me if I only import finished products?
Yes, but a narrow part of it. You must not place products containing restricted substances above Annex XVII limits, you must communicate SVHC presence above 0.1%, and you may need to notify SCIP. The bulk of REACH governs chemical manufacturers, not you.
Is there such a thing as a REACH certificate?
No. No authority issues one. What suppliers call a REACH certificate is a test report or a self-declaration — both useful, neither official, and both needing their scope checked.
Does the 0.1% threshold apply to the whole product?
No, and this is the commonest mistake. It applies per component article. A small part containing an SVHC can put you over even when the substance is negligible against total product weight.
How much does REACH testing cost?
It varies with scope and how many substances you screen. Commercial labs quote per test; some national public health institutes are considerably cheaper. In my experience a material-safety assessment came to roughly €40 per product, quoted per batch — but get your own quote rather than relying on my figure.
Do I need to register with ECHA?
Almost certainly not, if you import finished articles. Registration applies to manufacturers and importers of substances at or above one tonne per year. SCIP notification is a separate, lighter obligation and may still apply.
What happens if my product turns out to be non-compliant?
Market withdrawal, fines, and customs seizure at the border. As the importer of record, the liability is yours — not the factory's.
Where this fits
REACH is one layer of a bigger problem: developing a product with a factory you've never met, in a category you're new to, without getting taken. That's what Private Label from Zero teaches end to end — from finding a factory to passing EU compliance to launching your product.
Related reading: Do I Need CE Marking to Sell in the EU? · GPSR for Small Sellers: What the EU Rules Actually Require
This is one module of a much bigger problem
Developing a product with a factory you've never met, in a category you're new to, without getting taken. That's what Private Label from Zero teaches end to end.
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