Suppliers of consumer products are required to communicate information on certain chemicals in consumer products. These obligations fall under the REACH regulation whether you import the goods from a non-EU country or from another EU country.

As a supplier you may be required to prove that you comply with the regulation, for instance in the form of a declaration of conformity, declarations concerning the use of substances of very high concern (SVHCs), supplier declaration for articles, or similar.

Consumer rights and supplier obligations under REACH
Consumers have a right to be informed of hazardous chemicals in products and articles, and the shops have an obligation to provide this information on request. It is the EU chemicals legislation REACH that stipulates these rights and obligations.

• Retailers of plastic or foam products must be able to provide information on plasticizers (phthalates) such as DEHP and BBP in the articles. This includes shoes, fitness balls, cycling shorts, bike equipment, carpets, mats, pillows, swimming and bathing equipment, electrical cables, etc.
• Resellers of electronic equipment such as cell phones, TV sets, shavers, vacuum cleaners, coffee brewers, etc. must for instance be able to supply information on bromated flame retardants, e.g. HBCDD, in the products.

Substances of very high concern (SVHCs)
Suppliers must inform their retailers, distributors, and resellers about particularly hazardous substances, including certain phthalates and bromated flame retardants. These particularly hazardous substances, also known as Substances of Very High Concern (SVHCs) are included on a special list (the candidate list) in REACH. Substances are added to this candidate list continuously. Suppliers must be able to give information on the substance name if one or more substances from the candidate list is present in an article above a concentration of 0.1% weight.

Because of these obligations, retailers may request information from their suppliers that the products are in compliance with the REACH regulation. In some cases the retailer demands such information provided by the supplier within 24 hours.

For suppliers of mixtures and preparations as for example coatings, inks, adhesives or cleaners, other obligations apply.

Watch out for misinformation
Unfortunately, it is not always possible to trust statements from sub suppliers:

• Test reports in which relevant substances have been omitted, for instance phthalates which are on the candidate list
• Statements claiming that problematic substances are not present in the product, however, analysis reveal that the substances are present in the product