and why an early compliance check is essential for importing into the EU: A step-by-step ECHA checklist for procurement teams importing chemicals into the EU
When suppliers in Asia send offers, they almost always state that the substance is “REACH registered”. At first glance this sounds reassuring, yet for procurement in Europe it is only an indication, not a confirmation. Under REACH, the responsibility for registration lies with EU manufacturers and importers – or with an Only Representative (OR) appointed by a non-EU manufacturer. In practice, if there is no OR, the EU importer carries the responsibility and the risk.
For this reason it is important to check early in the process whether a substance is correctly registered and whether the supplier is actually able to supply material under this registration. If this is overlooked, the consequences can be serious: blocked shipments, material that cannot legally be used, urgent re-sourcing of critical raw materials and potential enforcement by authorities. If you want support in finding and verifying compliant suppliers, our Procurement Discovery service helps procurement teams map and qualify chemical manufacturers globally.
This article provides a practical and structured orientation that allows importers to make a reliable first assessment within a few minutes. The structure is intentionally clear and designed as hands-on support for daily procurement work.
1. Substance identification: CAS and EC numbers provide clarity from the start
Before a registration can be evaluated, the substance in question must be clearly identified. Suppliers in Asia often use internal codes, brand names or marketing terms that are not precise. A secure identification is most reliably achieved through the CAS number and the EC number.
The ECHA substance database provides the most reliable starting point: https://chem.echa.europa.eu/
In the section “Identity” you will find the key information, including the CAS number, the EC number, synonyms and trade names. This prevents confusion and helps interpret offers from Asia correctly. The section “Other Identifiers” often contains additional references such as product families or specific brand names that support the identification process.
2. Existence check: The registration is an indication, not a confirmation
On the substance overview page the tile “REACH registrations” shows whether registrations exist and how many companies have submitted dossiers.
If registrations are displayed, it only means that the substance has been registered under REACH. However, this does not confirm that your specific supplier is authorised to supply this substance to the European Union. The existence of a registration is therefore a first indication, not a confirmation of supply capability.
3. Status check: Only active registrations are valid for import
The decisive step is checking whether a registration is active. In the tab “Registrants” it is possible to see which companies hold an active registration. Only active registrants are permitted to place the substance on the EU market.
For procurement this means: A registration number can only be used if it can be clearly assigned to an active registrant. If the registration is inactive, the substance may no longer be supplied through this company. This check often determines whether a supplier is suitable at all.
4. Understanding the supply chain: EU manufacturer or Only Representative
For importers it is useful to know whether a substance is produced within the EU or imported. Manufacturers outside the EU cannot register substances themselves. They must appoint an Only Representative located within the EU.
This can be identified in the tab “Registrants”. Entries from consulting companies, regulatory service providers or company names containing the reference “OR” indicate that the actual manufacturer is located outside the EU. This information helps to understand the registration and the structure of the supply chain more clearly.
5. Identifying manufacturers: Trade names as important clues
Even if a supplier does not disclose the manufacturer, the ECHA database often provides useful hints. In the section “Identity”, particularly under “Other Identifiers”, trade names or product references can be found that allow conclusions about the likely manufacturer. This is especially helpful when the origin is unclear in offers from Asia or when the registration is managed through an Only Representative.
6. The tonnage band: What the total market volume indicates and what it does not
The registered tonnage band of an individual manufacturer is not publicly available. ECHA only provides an estimated total tonnage band for all registrants of a substance. This information offers general market orientation but does not indicate how much volume a specific producer has registered or whether the available volume will meet your actual demand.
This aspect is important when working with producers in Asia, since registered volumes are often distributed across several customers. A small registered tonnage band can lead to supply limitations even if the registration itself formally exists. Therefore the available volume must always be clarified directly with the producer or the Only Representative. For importers sourcing directly from China, it becomes even more important to combine these REACH checks with structured supplier qualification.
7. Procurement control: What the supplier in Asia should confirm in writing
For a reliable decision, importers should request a number of key points in writing. These include the identity of the producer, the assignment of the product to the active registration and the realistically available annual volume. Ideally, the supplier also confirms the registered tonnage band or at least the range in which it lies. In addition, the supplier should explicitly confirm that only material from this registered producer will be supplied.
This level of transparency is essential because suppliers in Asia often work with several producers and the actual origin is not always clear. Only this level of documentation ensures that the delivered material corresponds to the verified registration and can be imported into the EU in compliance with REACH.
8. Conclusion: A clear orientation for a reliable first REACH compliance check
With a structured approach it becomes clear very quickly whether a supplier in Asia can deliver a substance in accordance with REACH. The process starts with identifying the substance, continues with checking the existence and status of registrations, and concludes with understanding the supply chain and clarifying the available volume. These steps provide importers with a sound basis for further decisions and create transparency in a sensitive regulatory environment. If you need support identifying REACH-compliant manufacturers or validating offers from non-EU suppliers, you can reach out to our team and leverage CheMondis – the smartest chemical platform to find, verify, and interact with new suppliers – for a structured Procurement Discovery project.
