What has to be true before a chemical product can be sold in the European Union, in the order the questions actually arrive. This page is about documentation. It is not legal advice, and it does not replace an assessment of your specific situation.
1. Establish what the substance is
Not the trade name — the substance. CAS number, EC number, and for mixtures the composition with concentrations. Everything downstream depends on this being right, and it is where the largest share of problems originate: a hydrate documented as anhydrous, a salt as the free acid, a technical grade as the pure compound.
2. Find out whether somebody has already registered it
REACH registration is per substance, per legal entity, above one tonne per year. A non-EU manufacturer cannot register directly — either your importer registers, or you appoint an Only Representative established in the EU. We are not that party and cannot act as one, but you need to know which route applies before anything else is worth doing.
Sources: Regulation (EC) No 1907/2006 (REACH), Articles 6 and 8, on EUR-Lex · ECHA database of registered substances
3. Check whether it is restricted at all
Some substances cannot be placed on the market for certain uses, or cannot be supplied to the general public, or require authorisation. Annex XVII restrictions and the candidate list are the two lists worth checking first. Finding a restriction at this stage costs a morning; finding it after the goods are in a warehouse costs the warehouse.
Sources: ECHA inventory of substances restricted under REACH (Annex XVII) · ECHA Candidate List of substances of very high concern
4. Classify it under CLP
Where a harmonised classification exists in CLP Annex VI, it is mandatory and it overrides your own assessment. Where none exists, you classify on the available data and have to be able to show your reasoning. This is the step that determines the label, the transport entries and half the safety data sheet.
Sources: ECHA — Annex VI to CLP, harmonised classification inventory · Consolidated CLP, Annex VI Table 3 (CELEX 02008R1272-20250901, PDF)
5. Produce the safety data sheet
Sixteen sections in the order set by REACH Annex II, in the official language of every member state where the product is sold. One substance, one language, one document — because that is what an inspector reads. What goes in each section.
Sources: Regulation (EC) No 1907/2006 (REACH), Article 31 and Annex II, on EUR-Lex · Commission Regulation (EU) 2020/878 on EUR-Lex
6. Produce the label
Pictograms, signal word, hazard and precautionary statements, supplier details, nominal quantity. The label has to agree with Section 2 of the sheet. When the two are produced separately they drift, and the drift is what gets noticed. CLP labels.
7. Sort out transport before you book it
Road, sea, air and rail each have their own rules and their own entries. The carrier reads Section 14 before accepting the goods, and a missing or inconsistent entry stops the shipment at the point where delay is most expensive.
8. Keep it current
Documentation is not a one-off. ATPs to CLP arrive regularly, the candidate list is updated twice a year, and a sheet that was correct at issue drifts out of date without anything visibly changing. Whoever owns the product has to own the review cycle too.
Sources: ECHA — Annex VI to CLP, updated with each ATP · ECHA Candidate List, updated twice a year
Where we fit, and where we do not
We do: steps 3 to 7 — restriction and candidate-list status, classification against the harmonised list, the safety data sheet, the label, and the transport entries, with the source shown for every value.
We do not: register substances, act as your Only Representative, sell or ship chemicals, or advise on customs classification. Where your situation needs those, you need a different party and we will say so.
Start at the cheapest point
Find out where you actually stand
If you already hold documentation, the free audit tells you which of these eight steps is incomplete. If you are starting from nothing, send the list of substances and we will quote the work.