There Is No Such Thing as a REACH Certificate: What ECHA Registration Actually Produces

The request arrives in supplier correspondence regularly: a European buyer asks for a REACH certificate, or a customs declaration requests REACH certification documentation, or a compliance team asks for proof of REACH compliance. The problem is that no such document exists. REACH — Regulation (EC) No 1907/2006 — is the EU chemical registration, evaluation, authorization, and restriction regulation administered by the European Chemicals Agency (ECHA). ECHA does not issue compliance certificates, does not certify substances or manufacturers, and does not produce anything called a REACH certificate. Foreign exporters who receive this request need to understand what the buyer actually needs, what REACH registration actually produces, and what documentation they should provide.

What REACH registration actually requires and what it produces

REACH requires companies to register chemical substances manufactured or imported into the EU above one tonne per year before those substances can legally enter the EU market. Registration is completed through ECHA's REACH-IT portal by submitting a Registration Dossier containing technical and scientific data about the substance. After ECHA conducts a completeness check and accepts the dossier, it issues a Registration Number — a 17-digit code in the format 01-XXXXXXXXXX-CC-XXXX. This registration number is the output of REACH registration. It is not a certificate. It is a number that confirms the substance has been registered at the declared tonnage band. This number, plus an updated Safety Data Sheet reflecting the registration, is what foreign exporters and their EU-based registrants should provide to buyers who request REACH documentation.

The Only Representative model for non-EU manufacturers

A non-EU manufacturer cannot submit a REACH registration directly. REACH requires that the registrant be a legal entity established in the EU or EEA. Non-EU manufacturers who want to maintain control of their registration — rather than leaving it to each EU importer individually — appoint an Only Representative (OR) within the EU. The OR registers the substance on behalf of the non-EU manufacturer and holds the registration dossier and registration number. EU importers of that substance who import under the OR's umbrella are counted within the OR's registration tonnage rather than needing their own registration. The Only Representative model is the standard compliance structure for foreign chemical manufacturers. The registration number is held by the OR; the non-EU manufacturer provides it to buyers to confirm compliance.

Authorization and restriction: what happens beyond registration

Some substances listed on REACH Annex XIV (the Authorization List) — Substances of Very High Concern including certain carcinogens, mutagens, reproductive toxicants, and persistent bioaccumulative substances — require authorization before being placed on the EU market or used above defined concentrations. Authorization is a separate ECHA process requiring a formal application with a chemical safety report and a socioeconomic analysis. If authorization is granted, ECHA publishes an administrative decision — not a certificate. Some substances are restricted under REACH Annex XVII, which prohibits or limits their manufacture, use, or sale under specific conditions. Restriction entries are directly applicable and do not require any separate application. Neither authorization decisions nor restriction compliance documents are certificates — they are regulatory records that should be referenced in supplier documentation.

What foreign exporters should actually provide to buyers

When a European buyer requests REACH documentation, the correct response is a package that includes: the REACH Registration Number for each relevant substance (assigned by ECHA after dossier acceptance), a current Safety Data Sheet (SDS) prepared in accordance with REACH Annex II and formatted for the EU market, confirmation of the Only Representative appointment if the non-EU manufacturer uses that model, and a declaration confirming that the substance is registered at a tonnage band sufficient to cover the volumes being supplied. Providing a self-generated document titled REACH Certificate without the backing of an actual ECHA registration number, or providing documentation from a third-party service that issues commercial REACH compliance statements without underlying ECHA registration, does not satisfy actual REACH requirements and creates false compliance representation.

How FDABridge handles REACH registration for non-EU exporters

FDABridge manages REACH Only Representative appointment, registration dossier preparation, and ECHA submission for non-EU manufacturers whose substances are imported into the EU. We provide the REACH Registration Number to EU buyers and maintain the registration as volumes or substance compositions change. Visit fdabridge.com/reach-registration for specific information on our REACH services or fdabridge.com/contact to discuss your substance portfolio.