How to verify UK REACH compliance for materials

To comply with UK REACH, you must identify every chemical substance in your product and manufacturing process to ensure they are registered, authorised, or not restricted for use in Great Britain. Failure to comply can lead to significant fines, product recalls, or being barred from importing essential materials. If you import more than one tonne of a specific substance per year, or use restricted chemicals (like certain dyes or lead), you have immediate legal obligations under the Health and Safety Executive (HSE).

What is UK REACH?

UK REACH stands for the Registration, Evaluation, Authorisation, and Restriction of Chemicals. It is a set of regulations designed to protect human health and the environment from the risks posed by chemicals. Since Brexit, the UK has its own version of these rules, separate from the EU. It doesn't just apply to "chemical companies"—it applies to anyone making or importing physical products, from handmade soaps and candles to electronic components and textiles.

Step 1: Create a Material Inventory

Start by listing every single material that goes into your product and every chemical used in your workshop (like solvents, glues, or cleaning agents). You need to know exactly what is in these mixtures.

• Request Safety Data Sheets (SDS): Contact your suppliers and ask for the latest SDS for every material. Under law, they must provide these for professional users.
• Look for CAS Numbers: These are unique identifiers for chemicals. Use these numbers to search official databases rather than relying on brand names.

Step 2: Determine Your Role

Your responsibilities change depending on where you get your materials from:

Role	Description	Typical Responsibility
Manufacturer	You produce the chemicals yourself within the UK.	High: Full registration with the HSE is usually required.
Importer	You buy materials from outside the UK (e.g., China, USA, or the EU).	High: You are responsible for ensuring those chemicals are registered in the UK.
Downstream User	You buy materials from a UK-based supplier.	Lower: You must follow the safety instructions in the SDS, but the supplier handles registration.

Step 3: Check for Restricted or Prohibited Substances

Some chemicals are so dangerous they are banned entirely, while others are restricted to certain uses or concentrations. Even if you only import a small amount, these rules apply.

• The Candidate List: Check the HSE "Candidate List of substances of very high concern" (SVHC). If your product contains more than 0.1% of any of these, you may need to notify the HSE and your customers.
• Annex 17 (Restrictions): This list includes substances like lead in jewellery or certain phthalates in plastics. You must ensure your product does not exceed the allowed limits.

Step 4: Calculate Your Tonnage

Registration with the HSE is generally only required if you import or manufacture one tonne or more of a specific substance per year. If you are a small business or a solo maker, you are unlikely to hit this threshold for individual chemicals, but you must still comply with the restriction and authorisation rules mentioned in Step 3.

Step 5: Talk to Your Suppliers

If you import materials from the EU or elsewhere, your supplier might have appointed a "UK-based Only Representative" (OR) to handle the UK REACH duties for them. If they have, your life becomes much easier, as you are treated as a downstream user. Always ask: "Are the substances in this product compliant with UK REACH, and do you have a UK-based Only Representative?"

Top Tip: Don't assume that because a product is "safe" or "natural" it is exempt. Even essential oils or common metals are covered by REACH if they are used in a manufacturing context.

Useful Resources

The Health and Safety Executive (HSE) website is the primary source of truth for UK REACH. Use their "Find your role" tool to get a tailored list of your specific legal duties. If you find your product contains complex chemicals, consider hiring a regulatory consultant for a one-off audit to ensure you aren't accidentally breaking the law.