REACH: the reversal
REACH is the largest chemicals regulation project in history. Registration applies to manufacturers and importers of chemical substances at or above one tonne per year. Above the threshold, registration is mandatory — no exception. Registration with ECHA in Helsinki.
The SVHC Candidate List is the second key element for article producers. If you manufacture articles containing SVHC above 0.1 % by weight, with a total above one tonne per year, you must inform ECHA and notify your customers. As of 2026 the list contains over 240 substances.
The most common practical issue: SVHC screening happens once during product development and is not repeated. Between development start and market entry, the list may have grown. What was SVHC-free at the start may be SVHC-relevant at sale.
CLP and the safety data sheet
CLP transposes the UN GHS system into EU law. For certain substances the classification is harmonised and fixed in Annex VI. For these, no discretion applies.
The Safety Data Sheet per REACH Annex II is the central communication tool in the professional supply chain. 16 sections, in the right language, kept current. An outdated SDS is one of the most common industrial compliance problems.
The UFI requirement since 2022 covers all hazardous mixtures. The Unique Formula Identifier must appear in the SDS and on the label. Mixtures without a UFI cannot be marketed.
Swiss specifics
Switzerland applies its own chemicals law with separate notification duties. SDSs for the Swiss market must reference Swiss legal bases. An EU SDS is not complete for the Swiss market.
A REACH registration with ECHA does not automatically cover Switzerland. The SDS must be adapted for Switzerland — limited effort, but routinely overlooked.
Case: REACH tonnage threshold breached
A chemical formulator produces a specialty coating. The main active ingredient is bought annually — until two years ago below ten tonnes, no registration duty. Growth pushes the company across the ten-tonne threshold mid-year. Registration: not commissioned. ECHA performs a tonnage check. Verdict: no marketing until registration is complete. Registration process: nine months. Revenue loss in that period: EUR 1.2 million.
What was missing: a tonnage-threshold monitor in the ERP that triggers automatically as a substance approaches a REACH-relevant threshold. Implementation: two days of programming.