REACH Compliance for Chemical Exports to the European Union

Who Needs to Register

Any non-EU manufacturer wishing to export to the EU must either register substances themselves through an Only Representative (OR) established in the EU, or rely on the EU-based importer doing the registration. The OR route is preferred when serving multiple importers, as it consolidates regulatory cost and gives the exporter control over the dossier.

Registration is per substance, not per product. Volume bands determine the data requirements — 1–10 tonnes/year requires a basic dossier, 10–100 requires expanded toxicology, and above 1000 tonnes triggers full chemical safety reporting.

SVHC and the Candidate List

Substances of Very High Concern (SVHCs) sit on a Candidate List that ECHA updates twice a year. Once a substance is on the list, downstream users in the EU have notification and communication obligations whenever the substance is present above 0.1% w/w in an article. Substances may eventually be moved to Annex XIV, after which they require authorisation for any continued use — a process that is intentionally restrictive and expensive.

Practical Steps for Indian Exporters

Build the REACH dossier in advance of the first commercial shipment, not after a customer asks for it. Identify substances likely to head onto the Candidate List in the next 18–24 months by tracking ECHA registry of intentions, and develop substitution roadmaps before the regulatory pressure arrives. Most importantly, integrate REACH compliance documentation into your supplier qualification package — Indian exporters who can hand a European procurement team a complete regulatory bundle close deals faster than those who treat REACH as a one-off project.