REACH is four mechanisms with one name: registration, evaluation, authorisation and restriction. Most confusion about it comes from treating them as one thing. A substance can be registered and still restricted; it can be on the candidate list and not require authorisation; it can be exempt from registration and still need a safety data sheet.
The four mechanisms
Registration
A manufacturer or importer placing a substance on the EU market at one tonne or more per year per legal entity must register it with ECHA. The dossier grows with tonnage: at ten tonnes a chemical safety report is required. No registration, no market — the principle is often summarised as “no data, no market”.
Registration is a duty of the manufacturer or importer, not of the downstream user. It is also per legal entity, which is why the same substance can be registered by many companies.
Evaluation
ECHA and the Member States examine dossiers and, where warranted, examine substances. Evaluation can require more testing, or feed a substance forward into authorisation or restriction. It is a process, not a status a substance carries on a label.
Authorisation
Substances of very high concern can be placed on Annex XIV, the authorisation list. After a sunset date, using or placing such a substance on the market requires a specific authorisation for a specific use. Annex XIV is a short list — being on it is a significant fact about a substance.
Being on the candidate list is a different and weaker status, and the two are frequently conflated. See SVHC and the candidate list.
Restriction
Annex XVII restricts specified substances in specified uses, sometimes above a concentration threshold, sometimes for particular applications, sometimes for supply to the general public. A restriction is not a ban on the substance; it is a ban on a use.
Reading an Annex XVII entry carefully matters, because the restricted use is usually much narrower than the headline suggests.
Who is responsible for the safety data sheet
Article 31 places the duty on the supplier placing the substance or mixture on the market. That is the manufacturer, importer, downstream user or distributor who supplies it — not the customer, and not whoever prepared the paperwork.
Two consequences follow, and both are routinely misunderstood.
First, buying a document does not transfer the obligation. A sheet prepared by a third party supports the supplier’s assessment; the supplier still answers for it.
Second, there is no tonnage threshold for the safety data sheet. Article 31(1) sets no minimum quantity. A five-gram vial and a two-hundred-kilogram drum carry the same hazard communication duty, even though only one of them may trigger registration.
Language
Article 31(5) requires the sheet in an official language of each Member State where the material is placed on the market, unless that State provides otherwise. This is why a single English document is not automatically sufficient for a shipment into several countries, and why hazard and precautionary statements must take their official wording in each language rather than being translated freshly.
Extended safety data sheets
Where a substance is registered at ten tonnes or more per year and a chemical safety report has been prepared, the relevant exposure scenarios are annexed to the sheet. The result is an extended safety data sheet — an e-SDS. The core sixteen sections are unchanged; the scenarios are attached to them.
REACH is not CLP
REACH governs registration and market access. CLP — Regulation (EC) No 1272/2008 — governs classification, labelling and packaging. The safety data sheet sits at the junction: its format comes from REACH Annex II, and the classification it reports comes from CLP.
Transport classification is a third system again, following ADR, RID, ADN, IMDG and ICAO/IATA. A substance can be hazardous under CLP and unregulated for transport, and the reverse also happens. Section 14 of a safety data sheet is the only place transport rules apply.
Reading REACH status on a MolGod card
Every substance page states inventory status against seven lists in five jurisdictions, including REACH Annex XIV and the SVHC candidate list, and names the classification source. Where the status is not established, the page says so instead of implying that nothing applies.
Legal basis: Regulation (EC) No 1907/2006 (REACH), in particular Articles 31 and 33 and Annexes II, XIV and XVII. Classification terms follow Regulation (EC) No 1272/2008 (CLP). This page explains the framework and is not legal advice about a specific material or supply chain.