EU RECHA: Do you import dangerous or controlled substances or mixtures? Before placing a substance or mixture on the EEA market, you must determine whether it is hazardous by applying the classification criteria specified in the CLP regulations. Regardless of the quantity you provide, you need to perform this operation on each substance individually or in a mixture.

All hazardous substances and mixtures must be classified, labeled, and packaged

Classifying a substance or mixture as hazardous can trigger specific labeling and packaging requirements. You must notify ECHA of each individual or mixed hazardous substance placed on the market within one month after placing the product on the market. You must provide relevant information in the safety data sheet and use hazard labels to convey risks and ensure that your customers handle them safely.

Highly concerned about substances

REACH sets standards for identifying substances of high concern to human health and the environment (SVHC). Substances that meet these standards have been identified. These substances are included in the authorized candidate list updated and published on the ECHA website in June and December each year.

This is the first step of the REACH authorization process, aimed at controlling the risk of the most dangerous substances on the EEA market and ultimately replacing them with feasible and safer alternatives.

If the substance you import individually or in combination is identified as a substance of high concern and added to the authorized candidate list, you will have an additional obligation to convey information about the safe use of the substance to your customers.


You can continue to supply the substance, but you must pay attention to whether it has been added to the authorization list. This may only be a matter of time, and you can choose to give up highly focused substances before the law requires you to do so, in order to gain a commercial advantage.


Substances of high concern that require authorization

Substances of high concern that have been moved from the candidate list to the authorized list cannot be placed on the EEA market for use after the given 'sunset date' unless:

You or your direct downstream users have been granted authorization for specific uses of the substance

General or specific exemptions apply, for example, if you use the substance for scientific research and development

No matter how many substances are used, authorization is required.

If your substance is on the authorized list and does not apply for exemption, you must choose whether to:


Stop placing it on the market, or

Apply for authorization, or

Investigate the possibility of granting authorization to direct downstream users

Whether to apply for authorization is a business decision that depends on the importance of the substance, the possibility of using alternative substances or technologies to replace it, the cost of applying for authorization, the benefits and risks of continued use.


Restricted substances

Substances that pose unacceptable risks to human health and the environment are restricted. This may mean:


Comprehensive prohibition

Restricting marketing and specific uses, or

Limitations on the concentration level of substances in the mixture

One example is the limitation of toluene in adhesives or paint used by the public.


You must comply with these restrictions. You need to be aware of any restrictions and monitor upcoming restrictions related to the substances you import. ECHA will release information and conduct public consultation before making a restriction decision.