EU Regulatory Regime · High
REACH — Registration, Evaluation, Authorisation, Restriction of Chemicals — importer obligations + worked example
Status
Status: Active since 2007. Key dates: SCIP database notification mandatory since 5 January 2021 for articles containing SVHCs.
What you must do as the importer
Register substances >1 tonne/year with ECHA before import. For articles (any HS chapter): notify ECHA if Substance of Very High Concern (SVHC) is present in concentration >0.1% w/w and total exceeds 1t/year. Annex XVII restrictions (e.g., chrome VI in leather, lead in jewellery) apply universally — non-compliance means the goods cannot be placed on the EU market.
What goods are covered
- 28 — Inorganic chemicals
- 29 — Organic chemicals
- 32 — Tanning, dyeing extracts; pigments
- 33 — Essential oils, perfumery, cosmetics
- 34 — Soap, organic surface-active agents, cleaning preparations
- 35 — Albuminoidal substances; modified starches; glues
- 36 — Explosives; pyrotechnic products; matches
- 37 — Photographic or cinematographic goods
Worked example: a typical shipment that triggers
A €50,000 shipment of machinery (HS 280000) from CN into the EU triggers REACH — Registration, Evaluation, Authorisation, Restriction of Chemicals. The customs duty + VAT are calculated as normal — but on top of that, the importer must satisfy the obligations above before the goods can be placed on the EU market.
Non-compliance is not a duty event — it is a market-access event
A common misunderstanding: importers focus on duty + VAT and treat compliance as a tickbox. EU customs increasingly hold goods at the border for missing documentation (DDS for EUDR, CBAM declarant status for steel/aluminium, EU Responsible Person for cosmetics). Holds become storage charges; storage charges become forced re-export. Validate before booking the freight.
Related OrcaTrade resources
See whether this regime applies to your specific shipment
Six questions, all four calculators (sourcing, routing, customs, warehouse), full landed cost — with this regime flagged on your specific HS code if applicable.
Build my plan with this regime checked →