REACH Certificate of Conformity vs. REACH Declaration: What EU Importers Actually Need

Every week, some version of the same question arrives from a client preparing to enter the EU market: “Our supplier sent us a REACH certificate — are we covered?”

Usually, the answer is: partially, and probably not in the way you think.

The confusion is understandable. The REACH Regulation (EC) No 1907/2006 is one of the most ambitious chemical safety frameworks ever enacted, covering more than 22,000 registered substances and touching virtually every product category from cosmetics to construction materials. But nowhere in that regulation does the phrase “REACH Certificate of Conformity” actually appear. Neither does “REACH compliant” as a defined legal status. And that gap — between what suppliers send and what the law actually requires — creates real compliance exposure for companies selling into EU markets.

Let’s unpack what these documents are, what they’re genuinely worth, and what your actual legal obligations look like.

Why “REACH Compliant” Is Not a Legal Category (But Every Buyer Keeps Asking for It)

REACH doesn’t award certifications. There’s no European Chemicals Agency (ECHA) stamp of approval, no accreditation body issuing passes, no official REACH certificate number you can verify. What REACH does is impose a structured set of legal duties on specific actors in the supply chain — manufacturers, importers, and downstream users — based on the substance in question, the tonnage handled, and the role each actor plays.

So when a supplier in South Korea or Brazil sends you a document labeled “REACH Certificate of Conformity,” they are making a self-declaration. That document may be thoughtfully prepared, grounded in systematic substance screening against current SVHC data and Annex XVII restriction entries. Or it may be a PDF template downloaded from the internet and last refreshed sometime in 2021. From the certificate itself, you genuinely cannot tell.

This distinction matters because, as an EU importer, REACH obligations sit with you. Article 7 of the regulation makes importers of articles responsible for notifying ECHA when an article contains a Substance of Very High Concern (SVHC) above 0.1% by weight and when the total tonnage of that SVHC across all your imports exceeds 1 tonne per year. Article 33 additionally gives any downstream customer the right to request SVHC information about an article you’ve supplied — and you have 45 days to respond. A certificate received from a non-EU supplier doesn’t transfer those obligations away from you.

The ECHA Candidate List currently includes 242 SVHC substances as of early 2025, updated twice annually. Any REACH CoC issued more than six months ago may already be referencing an outdated version of that list.

What a REACH Declaration Actually Contains — and What Makes One Credible

A proper REACH declaration is a supplier-issued statement attesting that specific chemical substances are absent from, or present below threshold levels in, a given product or material. The most defensible versions include:

• The exact SVHC Candidate List version screened against, with the publication date
• The screening methodology — whether that’s XRF analysis, GC-MS testing, Chemical database cross-referencing, or a combination
• Explicit confirmation of Annex XVII restriction compliance for substance categories relevant to the product type
• Substance groups confirmed absent or present below 0.1% w/w, named specifically rather than generically
• The signatory’s name, professional role, and direct contact details for follow-up queries

The weakest version — still common from suppliers in markets where REACH is less familiar — states simply that “this product is REACH compliant.” That document is, practically speaking, worth very little during an enforcement review. It won’t satisfy a notified body auditing your product safety file. It won’t hold up if the DGCCRF or a national market surveillance authority investigates. And it won’t protect your business if a restricted substance turns up in your product during customs sampling.

For higher-risk product categories — cosmetic ingredients, textiles, toys, electrical equipment, articles with complex polymer blends — we typically advise requesting a supplier declaration alongside third-party analytical data. X-ray fluorescence (XRF) screening is fast and economical for metal-containing SVHCs like lead, cadmium, and hexavalent chromium. For phthalates, polycyclic aromatic hydrocarbons (PAHs), or certain halogenated flame retardants, gas chromatography-mass spectrometry (GC-MS) is the appropriate analytical route.

The REACH CoC: Where It Fits and Where It Falls Short

A REACH Certificate of Conformity is essentially a formalized, more structured version of a REACH declaration — issued on company letterhead, explicitly referencing the regulation and relevant annexes, and typically accompanied by supporting test reports or SDS references. In the specialty chemicals and polymer compounding sectors, CoCs are part of standard B2B practice and carry genuine weight.

Where a REACH CoC genuinely adds value is within the Safety Data Sheet (SDS) ecosystem. Under REACH Annex II, as updated by Regulation (EU) 2020/878, hazardous substances must be accompanied by an SDS disclosing SVHC status in Section 15. When a substance has a compliant SDS from its manufacturer — referencing registration status, tonnage band, and known SVHC classification — and that registration can be independently verified via ECHA’s public substance database, you have a meaningful documentation basis.

Where CoCs consistently fall short: they cannot substitute for direct ECHA notification when Article 7(2) obligations apply. If you import more than 1 tonne/year of articles containing an SVHC above 0.1% by weight, you must notify ECHA directly. No supplier CoC fulfills that obligation on your behalf, regardless of how detailed or well-intentioned the document is.

There’s also persistent confusion around the “Only Representative” (OR) mechanism. Under REACH Article 8, a non-EU manufacturer can appoint an EU-established Only Representative to handle registration obligations, which effectively removes the importer from the registration chain. But that relationship requires a formal, ECHA-recognised OR appointment — a supplier’s CoC doesn’t create it, reference it, or imply it. We regularly encounter importers who’ve assumed OR status is in place when no such arrangement exists.

What EU Importers Are Actually Obligated to Verify

Here’s the practical verification framework that makes regulatory sense for any company importing articles or chemical mixtures into the EU:

1. Confirm SVHC screening is current. The ECHA Candidate List was updated in January 2025, bringing the total to 242 substances. Supplier documentation referencing an older version should be flagged for re-screening, particularly if your product category includes polymers, textiles, or surface coatings.

2. Understand your tonnage thresholds. The 1 tonne/year notification threshold under Article 7(2) is cumulative across all articles containing the same SVHC, not per SKU. Companies importing multiple product lines that each contain trace amounts of the same substance can cross that threshold without recognising it.

3. Know who registered what. ECHA’s public database allows you to verify registration status by substance name or EC number. If a substance in your supply chain isn’t registered and you’re importing above the 1 tonne/year threshold, registration obligations may fall to you as the importer of record.

4. Maintain documented traceability. French customs authorities and the DGCCRF have both intensified REACH enforcement activity over the past three years, with particular attention to documentation quality. Can you produce an SDS, a supplier declaration referencing current SVHC data, and analytical test evidence if challenged? A folder of generic CoCs won’t satisfy that standard in an inspection.

5. Verify Annex XVII restrictions independently. There are currently more than 70 restriction entries in REACH Annex XVII, covering everything from lead in jewelry to CMR substances in consumer textiles. Each restriction has specific concentration limits, article categories, and use conditions. Suppliers outside the EU — unfamiliar with specific market-level enforcement priorities — may not address all relevant entries in their documentation.

Building a Documentation Chain That Holds Up Under Scrutiny

The practical objective for any EU importer is a documentation package that would survive an enforcement audit without requiring you to chase suppliers under time pressure. In our experience, that means:

• A compliant SDS for each relevant substance or mixture — in French for products sold in France, per REACH Annex II requirements — updated within the past two years
• A supplier REACH declaration explicitly referencing the current SVHC Candidate List version and the screening methodology applied
• An internal SVHC tonnage calculation across your full product range to determine whether Article 7 ECHA notifications are required
• Third-party analytical data for high-risk substance categories where self-declaration creates unacceptable risk
• A documented log of any Article 33 customer information requests and your responses, with timestamps

Companies entering the EU from North America or Asia often arrive with robust quality management documentation — ISO 9001 certificates, factory audit reports, COA packages — but thin chemical compliance documentation. Those aren’t interchangeable. A quality certificate tells you something meaningful about process consistency. It says nothing about the SVHC status of the polyurethane foam in your product’s seat cushion.

Building a defensible documentation chain from scratch typically takes 6 to 12 weeks for any product range of real complexity, depending largely on how responsive your supply chain is. Starting that process in parallel with market entry planning, rather than as a reactive exercise after customs clearance flags a shipment, is a considerably less stressful way to enter the EU market.

And if your suppliers resist providing substance-level data, treat that resistance as a risk signal worth investigating — not a procedural inconvenience to work around.

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Written by Sam Sammane, Founder, Care Europe. Learn more about our team

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Related from our network

• Supplier qualification and COA verification for chemical raw materials — Androxa’s testing specialists support supply chain due diligence for companies navigating complex regulatory documentation requirements in global markets.
• ISO 17025-accredited third-party testing for REACH-relevant substances — Independent analytical testing for SVHCs, restricted substances, and contaminants to support your EU compliance documentation.