REACH Non-Compliance Found in Imported Products
The Enforcement Forum of the European Chemicals Agency (ECHA) has identified continued non-compliance with the REACH Regulation in imported substances, mixtures and consumer products following an EU-wide targeted enforcement project.
The inspections revealed that one out of three substances in imported mixtures lacked the required REACH registration. In addition, restricted hazardous substances were found in several imported consumer products above the permitted limits.
Helsinki, 10 December 2025 – Inspectors from 29 EEA countries carried out 2,603 targeted inspections to verify compliance with REACH requirements on registration, restrictions and authorisation for imported products.
Enforcement Actions and Key Findings
Many inspections were conducted in close cooperation with customs authorities and national enforcement bodies, supporting the development of more effective methods to control the compliance of imported products with EU chemicals legislation.
According to Henrik Hedlund, Chair of the Enforcement Forum’s working group, coordinated enforcement activities play a crucial role in protecting human health and the environment by preventing non-compliant products from entering the EEA market. At the same time, these actions contribute to fair competition and a level playing field within the EU single market.
The project highlighted the importance of well-designed sampling and targeting strategies in enforcement activities. The results also showed that importers must be aware of their REACH obligations before placing products on the EU market. Importers are encouraged to obtain analytical reports or other evidence demonstrating REACH compliance prior to import.
Almost all non-compliant products detected before release for free circulation were either denied entry to the EEA market or allowed only after corrective measures were implemented.
Registration Requirements
When assessing compliance with REACH registration obligations:
One third of substances in imported mixtures were found to be unregistered
7% of substances imported on their own were missing registration
These non-compliance rates are higher than those identified in previous enforcement projects. The Forum also observed that many importers of mixtures were not fully aware of the substances contained in the products they placed on the market.
Restriction Requirements
More than 1,300 imported mixtures and consumer products were checked for compliance with REACH restriction requirements. Inspectors found that 16% of the products contained restricted hazardous substances in breach of the applicable conditions, such as exceeding permitted concentration limits, posing a potential risk to human health.
Most inspections focused on imported jewellery, particularly for the presence of nickel, cadmium and lead, while toys and textiles were also frequently inspected. The results indicate no significant improvement in jewellery compliance compared to previous findings, with nickel remaining a persistent issue.
Authorisation Requirements
Enforcement authorities also verified compliance with REACH authorisation obligations for imported substances of very high concern (SVHCs) subject to authorisation. Out of 21 inspected cases, four were found to lack a valid authorisation or had expired authorisations.
Conclusion
The inspections targeted product groups where non-compliance was expected and therefore do not represent the overall non-compliance rate of all imports into the EEA. However, the findings clearly demonstrate that REACH enforcement on imported products remains a priority and that importers must take proactive steps to ensure compliance before market entry.