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REACH and Chemical Restrictions: What China Exporters Need to Know

REACH applies to the importer, not the factory — here is what that distinction actually means in practice.

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is an EU regulation, but it reaches products made anywhere, including China, the moment they are placed on the EU market. The legal obligation sits with the EU-based importer, not the overseas factory — which surprises buyers who assume compliance is purely the supplier's problem.

In practice, REACH compliance for a finished consumer product usually means confirming the product does not exceed restricted-substance thresholds under Annex XVII (things like certain phthalates, nickel release from items with skin contact, or specific flame retardants) and, for some product categories, checking Substances of Very High Concern (SVHC) candidate list obligations if a component contains one above 0.1% by weight.

This is distinct from, and sits alongside, product-specific regulation — a toy still needs EN71 testing, cosmetics still need their own safety file, REACH is the chemical-restriction layer underneath all of it.

The UK runs a parallel but separate regime (UK REACH) post-Brexit, so a product cleared for the EU market under REACH is not automatically cleared for the UK, and the two compliance files should be requested and checked separately rather than assumed interchangeable.

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Reference sources

External standards bodies and government sources, linked for reference. Transeasy is not affiliated with these organisations.

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