Import of chemical products to the EU

Regulation (EU) 2021/167, which amends the Enforcement Regulation (654/2014), was adopted on 10 February 2021.

In order to be imported into the EU, goods must adhere to technical, safety, and labeling standards. Products that are intended for consumer use must meet the General Product Safety Directive (2001/95/EC), which includes:

  • *general safety requirements
  • *and specific responsibilities for manufacturers and distributors. These responsibilities include informing consumers about potential risks associated with the product and taking necessary measures to prevent such risks. These obligations apply to all professionals involved in the supply chain.

Chemicals and articles are subject to different provisions under REACH. Chemicals generally require REACH registration and SDS. Articles require SVHC disclosure and REACH-restricted substances screening.

If you import chemicals to EU, you will have two choices towards REACH compliance: do your own registration or buy products from REACH compliant suppliers. Please find below a few tips to guide you and help you achieve REACH compliance:

  • *Contact the Only Representative of your suppliers and get your goods certified

The OECD has compiled a summary of common violations of REACH regulations and associated penalties across European Union member countries. To evade these penalties, importers within the EU are advised to reach out to their supplier’s only representative and obtain certification for imported goods.

  • *Make sure to ask for an REACH compliant SDS

The SDS sections have been determined by REACH, and it is necessary to update them to meet the requirements of the regulation since its implementation in 2007. Importers should keep in mind to either obtain an SDS that adheres to REACH standards or create one themselves.

  • *The first stage of CLP compliance : C&L notification

CLP, which is short for Regulation (EC) No 1272/2008 on the Classification, Labeling and Packaging of substances and mixtures, brings the United Nations globally harmonized system (UN GHS) for chemical classification and labeling to Europe. It was put into effect on January 20th, 2009.

Under CLP, importers must notify the European Chemicals Agency (ECHA) about the identity, classification, and labeling of substances through a process known as “C&L Notification.” This information is added to a database called the Classification and Labelling Inventory.

Importers of substances subject to registration under REACH or those classified as hazardous must submit a C&L notification to ECHA before January 3rd, 2011 if the substance is placed on the EU market before December 1st, 2011. If this deadline is missed, notification should be made without delay.

The most pressing task for importers is to submit C&L notifications to ECHA. We recommend that EU importers submit their own notifications first.

If you need assistance with submitting C&L notifications, please contact us to help you fulfill your obligations under CLP.