REACH for FMCG

What is REACH?

REACH — Registration, Evaluation, Authorisation and Restriction of Chemicals — is a European Union regulation (EC No 1907/2006) that came into force in June 2007 and is administered by the European Chemicals Agency (ECHA). It establishes a comprehensive framework for the management of chemical substances manufactured in or imported into the EU, placing the burden of proof on manufacturers and importers to demonstrate that their substances are safe. REACH applies to substances on their own, in mixtures, and in articles, making it one of the most wide-reaching pieces of chemical legislation in the world.

REACH and the FMCG Industry

The Fast-Moving Consumer Goods sector sits at the intersection of chemistry and everyday life. From laundry detergents and shampoos to packaged foods and cosmetics, FMCG products routinely contain, or are manufactured using, chemical substances that fall within REACH's scope. Because these goods reach millions of consumers daily, the regulation places particular pressure on FMCG companies to trace, document, and control every chemical ingredient in their supply chains.

Consider a major household cleaning brand. The surfactants, preservatives, and fragrance compounds in a single dishwashing liquid may each require separate REACH registration dossiers, Safety Data Sheets (SDS), and downstream user communications. A personal care company manufacturing moisturising creams must verify that each raw ingredient supplier has registered substances above one tonne per year with ECHA, and must pass relevant hazard information along the supply chain. For food packaging manufacturers, the presence of substances of very high concern (SVHCs) in packaging films can trigger article notification obligations and customer communication requirements. In short, REACH touches virtually every product category in the FMCG universe.

The regulation also affects procurement decisions. An FMCG company sourcing a new preservative from a non-EU supplier must confirm that the importer has fulfilled registration obligations before that substance can legally enter the EU market. Failure to do so can result in regulatory penalties, product recalls, and significant reputational damage — outcomes that are especially costly for consumer-facing brands.

Key Requirements

• Registration of substances: Any substance manufactured in or imported into the EU in quantities of one tonne or more per year must be registered with ECHA. FMCG manufacturers producing large volumes of cleaning agents, personal care actives, or food-contact materials are directly affected by this threshold.
• Safety Data Sheets (SDS): Suppliers of hazardous substances or mixtures must provide up-to-date SDS to downstream users. FMCG companies receiving raw materials — such as fragrances, emulsifiers, or colorants — must collect, verify, and act on this documentation.
• Communication on Substances of Very High Concern (SVHCs): If an article contains an SVHC above 0.1 percent by weight, the producer or importer must notify ECHA and, upon request, inform consumers within 45 days. This is particularly relevant for packaging, adhesives, and printed materials used in FMCG products.
• Downstream User obligations: Companies that use chemicals in formulation or manufacturing must ensure that their use is covered by the supplier's registration and must communicate any new identified uses back up the supply chain.
• Authorisation for SVHCs: Substances placed on Annex XIV of REACH require specific authorisation from ECHA before they can continue to be used. FMCG formulators relying on certain phthalates or chromium compounds must either secure authorisation or find compliant alternatives.
• Restrictions on specific substances: Annex XVII restricts the manufacture, use, and sale of certain hazardous substances. For example, restrictions on specific azo dyes directly affect textile and packaging suppliers within FMCG supply chains.
• Substance information in supply chain: All actors in the supply chain must pass hazard and safe-use information downstream, ensuring that professional users and, where applicable, consumers can handle products safely.

Implementation Steps for FMCG Companies

1. Conduct a full chemical inventory audit. Map every substance and mixture entering your manufacturing processes, including raw materials, processing aids, cleaning agents, and packaging components. Assign CAS numbers and check registration status on the ECHA database. This baseline is the foundation for all subsequent compliance work.
2. Classify your role under REACH. Determine whether your company acts as a manufacturer, importer, downstream user, or distributor — or a combination of roles across different product lines. Each role carries distinct obligations, and misclassifying your position is a common source of non-compliance.
3. Verify supplier registration status. For every substance above the one-tonne threshold, confirm that your supplier has a valid ECHA registration number. Integrate this verification into your supplier onboarding and annual review procedures. Require suppliers to notify you immediately if their registration status changes.
4. Collect and manage Safety Data Sheets systematically. Implement a centralised SDS management system — whether a dedicated software solution or a structured document repository — to ensure that the most current SDS version is always accessible to formulation, production, and health-and-safety teams.
5. Screen articles for SVHCs. Work with your packaging, component, and raw material suppliers to identify any articles containing SVHCs above the 0.1 percent threshold. Establish a formal process for receiving SVHC declarations from suppliers and a procedure for notifying ECHA and responding to consumer inquiries.
6. Develop a substitution roadmap for restricted or authorised substances. Where your formulations rely on substances on the Authorisation List (Annex XIV) or subject to Annex XVII restrictions, initiate reformulation projects early. Lead times for finding compliant alternatives in personal care, household, or food-contact applications can be significant.
7. Train cross-functional teams. REACH compliance is not solely a regulatory affairs function. Procurement, R&D, operations, and marketing teams all make decisions that affect compliance status. Deliver targeted training so that each team understands how their work intersects with REACH obligations.
8. Monitor regulatory updates continuously. ECHA regularly updates the SVHC Candidate List, Authorisation List, and Restriction List. Assign a responsible person or team to monitor ECHA publications and assess the business impact of new listings within a defined timeframe after each update.

Frequently Asked Questions

Does REACH apply to finished consumer products sold in the EU, or only to chemical manufacturers?

REACH applies across the entire supply chain, including companies that produce or import finished articles — such as packaged goods, personal care products, and household cleaners — if those articles contain regulated substances. An FMCG brand that imports products from outside the EU is considered the importer under REACH and must ensure all applicable registration and SVHC notification requirements are met.

What happens if a substance used in my FMCG product is added to the SVHC Candidate List?

If ECHA adds a substance to the Candidate List and that substance is present in one of your articles above 0.1 percent by weight, you are required to notify ECHA within six months of the listing date. You must also be prepared to provide safe-use information to any consumer who requests it within 45 days. Beyond the legal obligation, many FMCG companies treat Candidate List additions as a trigger to begin substitution work, as SVHCs frequently progress to the Authorisation List over time.

How does REACH interact with other regulations relevant to the FMCG sector, such as the EU Cosmetics Regulation or food packaging legislation?

REACH operates alongside sector-specific legislation rather than replacing it. The EU Cosmetics Regulation (EC No 1223/2009) and food contact materials legislation set additional requirements for safety assessments, labelling, and prohibited substances within their respective scopes. In practice, an ingredient used in a cosmetic product may need to satisfy REACH registration requirements, the Cosmetics Regulation's safety assessment process, and any applicable food-contact migration limits if the packaging is a regulated material. FMCG compliance teams must map the full regulatory landscape for each product and ingredient combination.

Are small FMCG companies exempt from REACH obligations?

There is no general small-business exemption under REACH. However, the registration obligation applies to substances manufactured or imported at one tonne or more per year, which means very small-volume producers may fall below the threshold for some substances. Downstream user obligations — such as maintaining current SDS records, communicating SVHC information, and notifying uses not covered by a supplier's registration — apply regardless of company size. Small companies importing finished products into the EU face the same importer obligations as larger multinationals.

Summary

REACH compliance is not a one-time project but an ongoing operational responsibility that touches sourcing, formulation, manufacturing, and customer communication across the entire FMCG business. Companies that build robust chemical management systems, maintain close supplier relationships, and monitor regulatory developments proactively will be far better positioned to avoid disruption, protect their brands, and seize the competitive advantage that comes from genuinely transparent and responsible product stewardship. If your organisation has not yet completed a full REACH compliance review, now is the time to act — ECHA's enforcement activities and the growing scrutiny from retail partners and consumers make a reactive approach increasingly costly.