A recent EU-wide enforcement forum initiative has highlighted significant REACH compliance gaps in imported substances, mixtures, and consumer products. Inspections revealed that a substantial share of imported mixtures contained substances that were not registered under REACH, while certain consumer products exceeded legal limits for restricted hazardous substances.
Between enforcement authorities across 29 EEA countries, a total of 2,603 targeted inspections were carried out to assess compliance with REACH registration, restriction, and authorisation requirements for imported goods.
Coordinated enforcement and customs cooperation
The project results underline the importance of well-planned targeting and sampling strategies when monitoring imports. They also show that many importers are still insufficiently aware of their REACH obligations prior to placing products on the EU market. Authorities recommend that importers ensure access to analytical data or other reliable evidence demonstrating REACH compliance before import.
Most non-compliant products identified before release for free circulation were either denied access to the EEA market or allowed entry only after corrective measures were implemented.
Registration gaps in imported substances
Inspections focusing on REACH registration obligations found that approximately one third of substances present in imported mixtures were not registered as required. For substances imported on their own, registration was missing in around 7% of cases. These figures represent a higher non-compliance rate than observed in previous enforcement projects.
Authorities also noted that importers of mixtures often lacked sufficient knowledge of the substances contained in their products, increasing the risk of unintentional non-compliance.
Continued issues with restricted substances
More than 1,300 imported mixtures and consumer products were checked for compliance with REACH restriction requirements. Of these, 16% were found to contain restricted hazardous substances above permitted limits, posing potential risks to human health.
Jewellery was the most frequently inspected product group, particularly for nickel, cadmium, and lead content. Toys and textiles were also commonly targeted. The findings indicate that compliance levels in imported jewellery have not improved compared to earlier inspections, with nickel remaining a persistent issue.
Authorisation requirements also affected
Enforcement authorities also reviewed imported substances subject to REACH authorisation. Out of 21 cases examined, authorisation was either missing or no longer valid in four instances, highlighting ongoing challenges in this area as well.
What this means for importers
The inspections were deliberately focused on products with a higher expected risk of non-compliance and therefore do not represent the overall compliance level of all imports. Nevertheless, the findings clearly demonstrate the need for importers to proactively verify REACH compliance before products enter the EU market.
Importers should ensure that:
- All substances are properly registered where required
- Restricted substances comply with applicable concentration limits
- Authorisation obligations are met and kept up to date
- Supporting documentation is available and accessible
How Chementors can help
Chementors supports importers and non-EU manufacturers with assessing REACH obligations, verifying compliance of imported substances and products, and preparing for inspections by enforcement authorities. Proactive compliance checks can significantly reduce the risk of market access disruptions, penalties, and reputational damage.
If you need support with REACH compliance for imports, Chementors’ experts are ready to assist.
