Do I need to register packaging or finished articles under REACH?

Usually not. Articles need registration only when a substance is intended to be released from them, but the Article 33 communication and Article 7(2) notification duties still apply.

What does REACH Article 33 require?

If an article contains a Candidate List substance of very high concern above 0.1% weight by weight, the supplier must give the recipient enough information for safe use, at least the substance name.

Can a company in India register substances under REACH itself?

No. A non-EU manufacturer must appoint an EU-based Only Representative to register for it, or leave registration to its EU importers.

EU regulation guides

EU REACH for non-EU exporters

Q: Is REACH being rewritten?

Not in the current Commission mandate. In April 2026 the Commission said it would not table the REACH revision and would simplify through technical implementing changes instead.

REACH, Regulation (EC) No 1907/2006, governs chemicals in the EU, including chemicals inside the articles you ship. Most exporters meet it through disclosure, not registration.

Applies now · Last reviewed 22 October 2026 · General information, not legal advice

Does REACH apply to the goods I export?

Yes. REACH has applied in full for years to substances, mixtures and articles placed on the EU market, whoever made them.

What does Article 33 require?

If an article contains a substance of very high concern (SVHC) from the Candidate List above 0.1% weight by weight, the supplier must tell the recipient enough for safe use, at least the substance name.

Consumers can ask for the same information and must get it within 45 days. ECHA updates the Candidate List about twice a year, most recently in February 2026, so each update can change what you must disclose. Always check ECHA's current table.

Who carries the obligation?

Registration of a substance at 1 tonne a year or more falls on the EU manufacturer or importer.
A non-EU manufacturer can appoint an EU-based Only Representative to register for it, which takes that duty off its EU importers.
Article 7(2) requires notification to ECHA when an SVHC is above 0.1% in articles and above 1 tonne a year per producer or importer.
The EU supplier also notifies the SCIP database under the Waste Framework Directive.

What a non-EU supplier gives the EU buyer

An SVHC statement per article for content above 0.1% w/w, kept current against the Candidate List.
Safety data sheets for substances and mixtures.
REACH registration numbers, or the Only Representative's details, where you supply substances.
Evidence against any Annex XVII restriction that applies to the product.

Is REACH being rewritten?

Not in this Commission mandate. In April 2026 the Commission said it would not table the REACH revision.

How Truo handles REACH

Truo's compliance agent keeps each supplier's SVHC declarations and safety data sheets on the trade record against the product and specification they cover. When a specification changes or a declaration goes stale, it requests an update for a reviewer to accept.