REACH Compliance: What Every Indian Chemical Exporter Must Know

REACH principle is simple: No data, no market. The burden of proof for chemical safety lies with manufacturers and importers — not regulatory authorities. If a substance is not registered or properly exempt, it cannot be placed on the EU market.

How REACH affects Indian exporters: (1) Direct chemical exporters: EU importer must register substances imported in quantities above 1 tonne per year with ECHA. The Indian exporter should appoint an EU-based Only Representative who acts as registrant. (2) Downstream product exporters: If your textile, leather, electronic component, or plastic part contains chemicals, those chemicals must be registered or not restricted. EU REACH Article 33 requires notification to customers if products contain SVHC above 0.1% by weight.

SVHC — Substances of Very High Concern: ECHA Candidate List currently contains 240+ SVHCs. Common SVHCs affecting Indian exporters: lead compounds in PVC and electrical cables, chromium VI in leather, phthalates in plastics, PFAS in water-repellent textiles and non-stick coatings.

Practical compliance steps: (1) Map chemical inputs against the ECHA SVHC Candidate List and REACH Restriction Annex XVII; (2) Appoint an EU REACH Only Representative if exporting chemicals directly; (3) Obtain REACH compliance certificates from chemical suppliers; (4) Test finished products for SVHC at an ISO 17025 accredited laboratory; (5) Issue Article 33 SVHC notifications to EU customers; (6) Include REACH compliance declarations in EU buyer contracts.