A new investigation reveals that approximately one-third of industrial chemicals placed on the European market since 2010 fail to comply with the EU's REACH regulation, which requires manufacturers and importers to disclose hazardous properties and risks. This widespread non-compliance undermines the regulatory framework designed to protect public health and the environment, and poses significant compliance and reputational risks for chemical buyers and downstream users across the supply chain.
The scale of non-compliance
Researchers from the German Federal Institute for Risk Assessment (BfR) and the German Environment Agency (UBA) evaluated 1,814 industrial chemicals out of 2,408 substances produced or imported in volumes above 1,000 tonnes per year. Only 31% of these products met all legal requirements under REACH. The findings exclude biocides, pesticides, pharmaceuticals, and explosives.

Why this matters for chemical buyers
Non-compliant chemicals—including suspected carcinogens, neurotoxins, mutagens, and endocrine disruptors—have entered paints, textiles, toys, packaging, and construction materials. For importers and formulators, this means that substances purchased from non-compliant suppliers may carry hidden liabilities, including future regulatory restrictions, market bans, or reputational damage.
Regulatory and enforcement gaps

Dolores Romano, spokesperson for the European Environmental Bureau (EEB), stated: "The REACH regulation requires companies to inform authorities if substances are dangerous. If companies fail to report and authorities do nothing, we must fear health impacts from this lack of protection." A European Commission working document from March 2018 concluded that non-compliance hinders the identification of substances of very high concern and limits authorities' ability to protect the public.
What buyers should watch
Downstream users should verify that their chemical suppliers have submitted complete and accurate REACH registration dossiers, especially for high-volume substances. The EEB has called for the withdrawal of non-compliant substances from the market under the principle of "no data, no market." Buyers should also monitor updates from ECHA and national authorities, as enforcement actions may increase.

China sourcing context
While this study focuses on the European market, the findings have global implications. Many chemicals manufactured in China and exported to Europe are subject to REACH compliance. Chinese suppliers exporting to the EU must ensure their registration dossiers are complete to avoid shipment delays, penalties, or loss of market access. Importers should request proof of REACH compliance from their Chinese partners.
Source: Read the original report | Published: October 16, 2018
