REF-12: ECHA detects non-compliance in imports and recommends preventive measures

The REF-12 report by ECHA reveals significant non-compliance in substances and mixtures imported into the European Union, with the United Kingdom standing out among the most affected countries due to Brexit-related registration issues.

On December 10, the European Chemicals Agency (ECHA) published the REF-12 enforcement project report, focused on verifying compliance with the obligations under Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) for substances and mixtures imported into the EU.

During the inspection, products from 69 countries were reviewed, with particular attention to imports from China, the United Kingdom, Turkey, India and the United States. The analysis revealed that:

• China leads in the number of non-compliant substances, followed by the United Kingdom.
• The highest non-compliance rates were recorded for substances originating from Turkey, followed by those from the United Kingdom.
• Brexit has had a major impact on the UK’s compliance, as previous registrations became invalid and were not properly transferred or renewed.

Key recommendations

Importers are advised to:

• Consult national helpdesks before carrying out imports.
• Obtain updated analytical reports that prove compliance with registration, restriction and authorisation obligations under REACH.

ECHA also urges national authorities to strengthen enforcement by:

• Focusing on substances imported in mixtures.
• Ensuring compliance with restrictions, particularly in articles such as jewellery.
• Paying special attention to substances with recent authorisation sunset dates.

The report was presented during the open session of the Enforcement Forum, where regulatory challenges were discussed, including data protection under the Regulation (EU) Nº528/2012 concerning the making available on the market and use of biocidal products (BPR) and restrictions on synthetic polymer microparticles. Additionally, ECHA published the draft CoRAP 2026–2028, listing 27 substances for evaluation, including eight new entries compared to the previous plan.

European legislation is constantly evolving, requiring the sector to stay informed to ensure compliance for every product. At Siam, we remain committed to sharing the most relevant regulatory updates to provide reliable and accurate information. Our Chemeter software ensures that Safety Data Sheets and labels are always generated in line with the latest regulations, helping companies avoid export issues and customs delays due to outdated documentation.