REACH and UK REACH: What Indian Chemical Exporters Must File

REACH is the EU's chemicals regulation, and the single most misunderstood thing about it in Indian export circles is this: an Indian company can never register under REACH. The legal duty sits with the EU importer, or with an Only Representative appointed by you inside the EU. Everything your buyer asks of you — dossiers, safety data sheets, declarations, test reports — flows from that one structural fact, and so does the cost.

The fact that reframes everything

Regulation (EC) No 1907/2006 applies to substances manufactured in or imported into the EU. An Indian manufacturer is neither an EU manufacturer nor an EU importer, so it has no direct registration obligation and no ability to hold a registration in its own name. The duty lands on the legal entity bringing the goods across the EU border — your buyer.

That is why the commercial pressure comes back to you. Your buyer must register, pay ECHA fees and own the technical data. Faced with that, buyers do one of three things: refuse the business, price the compliance cost into your unit rate, or ask you to appoint an Only Representative so the burden shifts. Which of the three is on the table is the whole negotiation.

The threshold is one tonne per year per legal entity per substance — not per shipment, not per group. If three EU importers each take 0.8 tonnes annually, none crosses the threshold. If one takes 1.2 tonnes, that importer must register. Tonnage is counted per calendar year and aggregated across all of that entity's imports of the substance, not only what it buys from you.

Only Representative, or let the importer register?

An Only Representative (OR) is an EU-established person or company, appointed in writing by the non-EU manufacturer, who takes on the importer's registration duties for the volumes covered by that appointment. Once your OR registers, your EU customers become downstream users and are relieved of registering for the quantity you supply through it. ECHA requires the OR to have sufficient background in handling the substances, and to keep a separate ECHA account per non-EU manufacturer represented.

The commercial arguments run as follows.

• Appoint an OR when you sell the same substance to several EU buyers, when you want to keep your customer list and composition data out of your buyers' hands, when you are building volume and expect to cross one tonne with multiple importers, or when your buyers are traders who will not register at all.
• Let the importer register when you have one large, committed EU customer who already holds a registration for that substance, or when your annual EU volume is genuinely below one tonne per importer and likely to stay there.

On cost, ECHA's fee was raised 19.5% by Commission Implementing Regulation (EU) 2025/2067, in force from 05-11-2025. Standard individual-submission fees are now EUR 2,078 (1–10 t), EUR 5,585 (10–100 t), EUR 14,939 (100–1,000 t) and EUR 40,270 (above 1,000 t); joint submissions are lower. SME reductions are substantial — a small enterprise pays about EUR 457 for a joint 1–10 t submission, a micro enterprise about EUR 65 — and for an OR, SME size is assessed against the non-EU manufacturer it represents, so most Indian SMEs qualify. From 05-02-2027 SME status must be requested two months before submission.

The larger cost is not ECHA's fee. It is the letter of access to the joint submission data (often EUR 5,000 to EUR 50,000), testing where no data exists, and the OR's annual retainer.

Tonnage bands and what each one demands

Registration is a joint submission with other registrants of the same substance. You buy access to their data rather than repeating tests — vertebrate testing may not be duplicated. The dossier is prepared in IUCLID and submitted through REACH-IT.

When you are exporting an "article", not a substance

This is where exporters of finished goods get caught out. An "article" is an object whose shape, surface or design determines its function more than its chemical composition — a leather bag, a ceramic mug, a cotton dupatta, a brass handicraft, a cookware set. Articles need no registration, but three other duties bite.

• SVHC content. The Candidate List of Substances of Very High Concern stood at 253 entries after the February 2026 update. If any listed substance is present above 0.1% w/w of the article, obligations trigger.
• Article 33 communication. The supplier must pass sufficient information for safe use down the chain automatically to business customers, and to a consumer on request within 45 days, free of charge. In practice your EU buyer will demand a signed SVHC declaration from you so it can discharge this duty.
• SCIP notification. Any company placing such an article on the EU market must notify ECHA's SCIP database. Separately, Article 7(2) requires notification to ECHA where an SVHC is above 0.1% w/w and the total exceeds one tonne per year, within six months of the substance's Candidate List entry.

Recurring problems with Indian consignments: chromium(VI) and certain azo dyes in leather and textiles; lead and cadmium in ceramic glazes, enamelware and costume jewellery; phthalates in PVC-coated fabrics and footwear; nickel release in metal handicrafts and buckles; formaldehyde in wood-based handicrafts. Restriction (Annex XVII) bans or caps many of these outright, applies to imported articles regardless of tonnage, and is the provision on which non-compliant consignments are most often stopped. Authorisation (Annex XIV) works differently — it governs use inside the EU rather than imported articles, but it removes EU demand for anything made with a listed substance. If you supply textiles, see our note on GOTS certification, since a certified chain often already generates the test evidence buyers want.

CLP, labelling and poison centre notification

CLP (Regulation (EC) No 1272/2008) is separate from REACH and applies from the first gram. Substances and mixtures must be classified, labelled with the correct pictograms, signal word, hazard and precautionary statements, and packaged to CLP rules — in the official language of every member state where they are sold. Hazardous substances must be notified to ECHA's Classification and Labelling Inventory within one month of first placement on the market. One 2026 change: under Regulation (EU) 2024/2865, from 01-07-2026 ECHA publishes notifier names in the C&L Inventory unless a confidentiality justification was filed by 30-06-2026.

For mixtures classified for health or physical hazards, the importer or downstream user must submit a Poison Centre Notification in the harmonised Annex VIII format and print a Unique Formula Identifier (UFI) on the label. The transition for legacy national notifications ended on 01-01-2025, so consumer, professional and industrial uses are all now in scope. The UFI derives from your formulation, so the buyer needs full composition data from you, usually under a confidentiality arrangement.

A GB-bound consignment needs either a GB importer who registers, or a UK-based Only Representative — an EU OR does not cover Great Britain. GB CLP notification, a GB candidate list and GB restrictions run in parallel and are already diverging. Budget for two filings and two fee schedules if you supply both markets. On the EU side, the wider REACH revision was shelved in April 2026, while the "chemicals omnibus" reached provisional political agreement on 17-06-2026 — easing some B2B label readability rules and allowing digital labelling for small inner packaging, applying from 01-01-2030.

What an EU buyer will actually ask you for

1. A Safety Data Sheet in the 16-section EU format under REACH Annex II, in the language of the destination country — a US-format or Indian-format SDS will be rejected. Extended SDS with exposure scenarios where a CSR exists.
2. The REACH registration number or the OR's details, or written confirmation of who is registering and in whose name.
3. A signed, dated SVHC declaration against the current 253-entry list, with a commitment to update it at each revision.
4. An Annex XVII restriction compliance declaration covering the specific restricted substances relevant to your product category.
5. Third-party test reports from an accredited lab — azo dyes, chromium(VI), heavy metals, phthalates, formaldehyde, nickel release — batch-linked where possible.
6. Full composition data for mixtures, for UFI generation and PCN, usually under NDA.
7. CLP-compliant label artwork, plus sample labels for approval on consumer goods.
8. Consistent HS classification and commercial documents — see HS code classification and certificate of origin, since a customs description contradicting your SDS invites inspection.

Assemble these before the buyer asks. A supplier who produces a correct EU-format SDS and a current SVHC declaration on first request is treated very differently from one who takes six weeks. Compliance documents are also frequently written into LC document lists — see letter of credit.

Where OZIANT and ZJELL fit

OZIANT is a B2B cross-border marketplace that connects overseas buyers with Indian suppliers, so REACH questions typically surface during buyer qualification rather than after the order. ZJELL Limited, the group's export consulting arm, handles the registrations and compliance filings themselves — Only Representative appointment, dossier and SDS preparation, SVHC and SCIP work, CLP and poison centre notification. If you have an EU or UK enquiry on the table and are not sure which route applies, contact the team.