REACH registration: who must register a substance with ECHA, what it costs, and what a seller of finished goods owes instead

REACH registration is the duty to give ECHA, the EU chemicals agency, a file on a substance before it is made in the EU or imported into it. It sits on substances, not on finished products: a manufacturer or importer of a substance, “either on its own or in one or more mixture(s), in quantities of one tonne or more per year”, registers it (Art. 6(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 6, paragraph 1Click opens the article on EUR-Lex.). A shirt, a phone case or a bracelet is an article, and an article is registered only in the narrow case set out below (Art. 3(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 3Click opens the article on EUR-Lex., Art. 7(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 1Click opens the article on EUR-Lex.).

Who must register: the EU manufacturer or importer, from one tonne a year

ECHA names three kinds of registrant: an EU manufacturer or importer of a substance on its own or in a mixture, an EU producer or importer of articles that meet the criteria, and an only representative in the EU appointed by a business outside it. The law sets this out in Art. 6(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 6, paragraph 1Click opens the article on EUR-Lex. for substances and Art. 7(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 1Click opens the article on EUR-Lex. for substances in articles, and the rule behind both is “no data, no market”: a substance on its own, in a mixture or in an article “shall not be manufactured in the Community or placed on the market unless” it has been registered where registration is required (Art. 5Regulation (EC) No 1907/2006, REACH (chemicals)Article 5Click opens the article on EUR-Lex.).

Four points decide whether the duty reaches you.

• It counts the substance, not the product. The tonne is of one substance, whether it comes in on its own or inside one or more mixtures. A cleaner, a coating, an ink or an adhesive is a mixture; ECHA gives these as its typical examples (Art. 3(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 2Click opens the article on EUR-Lex.).
• It counts each registrant separately. The threshold is one tonne “per year” for “any manufacturer or importer”, and the bands are counted “per manufacturer or importer” (Art. 6(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 6, paragraph 1Click opens the article on EUR-Lex., Art. 12(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 12, paragraph 1Click opens the article on EUR-Lex.). One importer under one tonne does not register because a second importer of the same substance is above it.
• One substance, one registration. Manufacturers and importers of the same substance submit jointly: one lead registrant files the shared hazard data, and each registrant files its own identity, uses and tonnage (Art. 11(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 11, paragraph 1Click opens the article on EUR-Lex.).
• Polymers are outside it, but their monomers are not. REACH exempts polymers from registration (Art. 2(9)Regulation (EC) No 1907/2006, REACH (chemicals)Article 2, paragraph 9Click opens the article on EUR-Lex.). An importer of a polymer registers a monomer that no one earlier in the chain has registered, if the polymer holds 2% or more of it and the monomer reaches one tonne a year (Art. 6(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 6, paragraph 3Click opens the article on EUR-Lex.).

Some substances are out of scope or exempt. The text names: goods under customs supervision in temporary storage, in a free zone or free warehouse with a view to re-export, or in transit, without any treatment (Art. 2(1)(b)Regulation (EC) No 1907/2006, REACH (chemicals)Article 2, paragraph 1, point (b)Click opens the article on EUR-Lex.); substances in medicinal products, food and feed, to the extent that they are used there (Art. 2(5)Regulation (EC) No 1907/2006, REACH (chemicals)Article 2, paragraph 5Click opens the article on EUR-Lex.); the substances listed in Annexes IV and V, and registered substances that are re-imported or recovered in the EU on the conditions set out (Art. 2(7)Regulation (EC) No 1907/2006, REACH (chemicals)Article 2, paragraph 7Click opens the article on EUR-Lex.). On-site and transported isolated intermediates are exempt from the general registration chapter and have their own, lighter registration (Art. 2(8)Regulation (EC) No 1907/2006, REACH (chemicals)Article 2, paragraph 8Click opens the article on EUR-Lex., Art. 17Regulation (EC) No 1907/2006, REACH (chemicals)Article 17Click opens the article on EUR-Lex., Art. 18Regulation (EC) No 1907/2006, REACH (chemicals)Article 18Click opens the article on EUR-Lex.).

A seller outside the EU cannot register, and an only representative can do it for you

The registrant is a “manufacturer” or “importer”, and both definitions require a person “established within the Community” (Art. 3(9)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 9Click opens the article on EUR-Lex., Art. 3(11)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 11Click opens the article on EUR-Lex.). A producer of an article is a person who makes or assembles it “within the Community” (Art. 3(4)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 4Click opens the article on EUR-Lex.). A business outside the EU is none of these. ECHA says it plainly: REACH and CLP “only apply to legal entities established in the European Union” and the other EEA countries, and the duty lies “with the importers established in the European Union, or for REACH obligations, with the only representative”.

The only representative is the one way a non-EU business takes the registration into its own hands. A person established outside the EU who “manufactures a substance on its own, in mixtures or in articles, formulates a mixture or produces an article that is imported into the Community may by mutual agreement appoint” an EU person “to fulfil, as his only representative, the obligations on importers” (Art. 8(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 1Click opens the article on EUR-Lex.).

An only representative takes on more than the filing. It “shall also comply with all other obligations of importers”, needs “a sufficient background in the practical handling of substances and the information related to them”, and keeps up-to-date information on quantities imported and customers sold to, and on the supply of the latest safety data sheet (Art. 8(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 2Click opens the article on EUR-Lex.). ECHA adds that it may represent several non-EEA suppliers if it keeps each one’s information apart. The appointment is by mutual agreement; REACH does not make it a condition of selling into the EU, and the EU importer can register instead. The size test for fee reductions then looks at the non-EU business, not the representative (Regulation (EC) No 340/2008, Art. 12).

Substances in the articles you sell: registration is rare, three other duties are common

A producer or importer of articles registers a substance in them only if both conditions hold: the substance totals over one tonne per producer or importer per year, and it “is intended to be released under normal or reasonably foreseeable conditions of use” (Art. 7(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 1Click opens the article on EUR-Lex.). ECHA’s example is a scented toy, where the release is deliberate and has a function. ECHA reads “intended” as deliberately planned and with a function in the use of the article, so a substance that merely stays in the article, such as a dye fixed in fabric, does not meet the second condition. Nothing is due either where the substance has already been registered for that use (Art. 7(6)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 6Click opens the article on EUR-Lex.). ECHA can also require a registration by decision where it suspects a harmful release (Art. 7(5)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 5Click opens the article on EUR-Lex.).

Note the difference in the words: Art. 6(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 6, paragraph 1Click opens the article on EUR-Lex. says “one tonne or more” for a substance, and Art. 7(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 1Click opens the article on EUR-Lex. says “over one tonne” for a substance in articles.

What a seller of finished goods owes much more often is on the Candidate List side:

No notification is due where exposure of people and the environment can be excluded; the recipient gets instructions instead (Art. 7(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 3Click opens the article on EUR-Lex.). SVHC works through all three duties, the 0.1% count per component and the Candidate List. REACH compliance covers the importer routes for a finished article, and REACH Annex XVII the limits that bind the product itself.

Tonnage bands set how much data the registration holds

The band is the quantity per year per registrant. The dossier grows with it (Art. 12(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 12, paragraph 1Click opens the article on EUR-Lex.).

When a registered quantity reaches the next band, the registrant tells ECHA at once what additional information it will need (Art. 12(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 12, paragraph 2Click opens the article on EUR-Lex.). A change of band is also a reason to update the registration without undue delay (Art. 22(1)(c)Regulation (EC) No 1907/2006, REACH (chemicals)Article 22, paragraph 1, point (c)Click opens the article on EUR-Lex.).

Deadlines: the phase-in dates have passed, so registration comes before the first import

REACH gave “phase-in” substances, broadly those already on the EU market before REACH, a staggered timetable, on condition that they had been pre-registered (Art. 3(20)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 20Click opens the article on EUR-Lex., Art. 28(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 28, paragraph 3Click opens the article on EUR-Lex.). Three dates were set (Art. 23(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 23, paragraph 1Click opens the article on EUR-Lex., Art. 23(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 23, paragraph 2Click opens the article on EUR-Lex., Art. 23(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 23, paragraph 3Click opens the article on EUR-Lex.).

Each date applies to a substance that reached the quantity at least once after 1 June 2007.

All three have passed. What is left, for a substance that is not registered, is the basic rule: register before you manufacture or import (Art. 5Regulation (EC) No 1907/2006, REACH (chemicals)Article 5Click opens the article on EUR-Lex.). In practice it runs in this order.

1. Inquiry. A potential registrant of a non-phase-in substance, or of a phase-in substance it did not pre-register, asks ECHA whether the same substance is already registered (Art. 26(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 26, paragraph 1Click opens the article on EUR-Lex.).
2. Joint submission and data sharing with the other registrants of that substance (Art. 11(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 11, paragraph 1Click opens the article on EUR-Lex.).
3. Submission with the fee. ECHA checks completeness within three weeks (Art. 20(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 20, paragraph 2Click opens the article on EUR-Lex.).
4. Start of import. The registrant may start or continue if ECHA has raised no objection within three weeks after the submission date (Art. 21(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 21, paragraph 1Click opens the article on EUR-Lex.).

A first-time importer of a phase-in substance could still use the staggered dates by pre-registering within six months of its first import and no later than 12 months before the relevant deadline (Art. 28(6)Regulation (EC) No 1907/2006, REACH (chemicals)Article 28, paragraph 6Click opens the article on EUR-Lex.). For the 1 June 2018 deadline that cut-off was 1 June 2017, as ECHA states. That route is closed.

ECHA fees: what each band costs from 5 November 2025

The fees are set by Commission Regulation (EC) No 340/2008, as REACH requires (Art. 74(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 74, paragraph 1Click opens the article on EUR-Lex.). Implementing Regulation (EU) 2025/2067 of 15 October 2025 replaced its fee annexes with higher amounts, and they are in force from 5 November 2025, the date of the latest consolidated text. A submission that was already pending on that date keeps the old amount. The standard fees for a registration under Art. 6, 7 or 11:

Reduced fees for micro, small and medium enterprises are set in Table 2 of Annex I. Individual submissions cost:

A joint submission is cheaper again at each size. Annex I carries those figures too. The reductions are limited to SMEs, and REACH requires ECHA to set a reduced fee for them (Art. 74(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 74, paragraph 3Click opens the article on EUR-Lex.). A claim is made at the time of submission, and ECHA may ask for evidence at any time. A business that cannot show it qualifies pays the full fee and an administrative charge (Regulation (EC) No 340/2008, Art. 13). From 5 February 2027 the order changes: the business applies to ECHA for recognition of SME status at least two months before the submission, and a decision is valid for three years (Implementing Regulation (EU) 2025/2067, Art. 1(2), Art. 3).

Where no fee is charged. For a substance of 1 to 10 tonnes, no fee is levied when the dossier holds all the information of Annex VII (Art. 74(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 74, paragraph 2Click opens the article on EUR-Lex.). Where it does not, the Annex I fee for the band applies (Regulation (EC) No 340/2008, Art. 3(2)).

Paying. The fee is due within 14 calendar days from the date ECHA notifies the invoice. If it is not paid, ECHA sets a second deadline, and after that the registration is rejected. Where it is rejected for non-payment or for missing information, the fee already paid is not refunded (Regulation (EC) No 340/2008, Art. 3(5)-(7)).

Later changes cost money too. Moving up a band is an update with its own fee. Standard, individual submission: EUR 3,507 from the 1 to 10 band to the 10 to 100 band, EUR 9,353 from 10 to 100 up to 100 to 1,000, and EUR 25,332 from 100 to 1,000 up to above 1,000. Annex III lists the joint, SME and other update fees. Moving down a band costs nothing (Regulation (EC) No 340/2008, Art. 5(1) and Annex III).

These are ECHA’s fees. Data-sharing costs, testing, a consultant and an only representative’s own charge are separate, and the fee regulation does not set them.

What happens if you do nothing

A substance that needs registration “shall not be manufactured in the Community or placed on the market” without it (Art. 5Regulation (EC) No 1907/2006, REACH (chemicals)Article 5Click opens the article on EUR-Lex.). Import counts as placing on the market (Art. 3(12)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 12Click opens the article on EUR-Lex.). The duty lies with the EU importer, or with the only representative, and ECHA notes that EU importers turn to their non-EU suppliers for the information they need. Each EU country sets its own penalties, which must be “effective, proportionate and dissuasive” (Art. 126Regulation (EC) No 1907/2006, REACH (chemicals)Article 126Click opens the article on EUR-Lex.). A registrant must keep the information it needs for its duties for at least ten years after it last manufactured, imported or supplied the substance, and hand it to the authority on request (Art. 36(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 36, paragraph 1Click opens the article on EUR-Lex.).

What you can skip

What the law leaves open

• Who registers when a parcel goes from outside the EU straight to a consumer in the EU. The registrant must be established in the EU (Art. 3(7)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 7Click opens the article on EUR-Lex., Art. 3(11)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 11Click opens the article on EUR-Lex.), and no article of REACH names a consumer buying for personal use as an importer or a registrant. ECHA’s reading is that the duty lies with the importers established in the EU. The text names nobody for a direct parcel. Meanwhile, if a business in the EU takes the goods in, it is the importer and the registrant.
• How the tonne is counted when an only representative covers several importers. Art. 6(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 6, paragraph 1Click opens the article on EUR-Lex. and Art. 12(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 12, paragraph 1Click opens the article on EUR-Lex. count “per manufacturer or importer”, and the representative takes on the importer duties (Art. 8(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 1Click opens the article on EUR-Lex.). Art. 8(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 2Click opens the article on EUR-Lex. asks it to keep information on “quantities imported and customers sold to”. The text does not say in so many words how the band is counted for a representative. ECHA’s guidance does: each registration covers the total tonnage in the agreements between the representative and the one non-EU maker, and the data the dossier needs follow that total. One representative acting for several non-EU makers files a separate registration for each.
• Whether a hazardous mixture needs a classification and a label before the registration is complete. That sits in the CLP Regulation, not in REACH registration.