REACH Compliance: A Raw-Material Sourcing Guide

REACH compliance is one of the first questions a procurement team should resolve before sourcing a new raw material into the EU. The regulation shapes who can supply a substance, what documentation must travel with it, and which obligations land on you versus your supplier. This guide explains REACH from a sourcing perspective — not as a legal treatise, but as a practical checklist for buyers and formulators.

What is REACH and who does it apply to?

REACH is Regulation (EC) No 1907/2006, the EU regulation governing the registration, evaluation, authorisation and restriction of chemicals. For a buyer, it means that every substance brought into the EU above tonnage thresholds must be registered — by the EU manufacturer, the EU importer, or a non-EU producer’s appointed Only Representative — and that you should request the REACH status and a current safety data sheet (SDS) for every material you source.

REACH applies broadly: to substances on their own, in mixtures, and in some cases in articles. The core duty falls on whoever manufactures or imports a substance into the EU at one tonne or more per year. The principle behind it is often summarised as “no data, no market” — without a valid registration and the underlying safety data, a substance cannot lawfully be placed on the EU market above that threshold.

What does REACH mean when you source raw materials?

For a sourcing or R&D team, REACH translates into three recurring questions: is the substance registered, where in the chain does that registration sit, and do I have the SDS I need to use it safely and lawfully.

If you import a substance into the EU yourself, you are likely the importer and may carry the registration duty. If you buy that same substance from an EU-based distributor, the import has usually already happened upstream, and you are typically a distributor or a downstream user rather than the registrant. The substance does not change — your role, and therefore your obligations, do.

Who is responsible for REACH registration — manufacturer, importer or distributor?

Registration is concentrated on the parties that introduce a substance to the EU market. The table below maps the main REACH roles to who registers and the key obligation each role carries.

The practical takeaway for buyers: if you purchase inside the EU, your supplier is usually a distributor or downstream user, not the registrant. That does not mean nobody registered the substance — it means the registration sits further upstream, with the manufacturer, importer or an Only Representative. Part of due diligence is confirming that it does.

What should you ask a chemical supplier about REACH?

A short, repeatable due-diligence request keeps sourcing clean across every material and manufacturer. For each substance, ask your supplier to confirm:

• The REACH registration status of the substance and where in the supply chain the registration sits (EU manufacturer, importer or Only Representative).
• A current SDS with applicable exposure scenarios for your intended use.
• Whether the substance appears on the candidate list, authorisation list (Annex XIV) or under any restriction (Annex XVII) relevant to your application.
• The grade, origin and intended use so you can match the documentation to the material you actually receive.

How an independent EU distributor supports REACH-aware sourcing

The same substance can reach you through very different supply paths — and the REACH picture differs with each one. An independent EU distributor sits between the global manufacturer and your bench or plant, which is exactly where the registration and documentation questions get resolved.

Berstin positions as REACH-aware authorised EU distribution: we source named, world-class manufacturers and supply into the EU and MENA, and we treat REACH status and current documentation as part of every quotation. Commodities we move regularly — such as SLES (HS 3402.31), citric acid (HS 2918.14) and glycerine (HS 2905.45) — are quoted with the technical data and supply detail a compliant sourcing decision needs.

You can browse the full range on the products portfolio. Tell us the substance, grade, intended use and destination market, and we will respond with technical data, the supply path and indicative pricing — so you can confirm REACH status for your role before you commit. Confirm regional regulatory status for your market against the current SDS.