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Europe - REACh: numerous chemical non-conformities in imported articles

Posted in Innocuousness on 2020-10-16 by CTC
At the end of September 2020, the European Chemicals Agency (ECHA) published the report of a European project on the implementation of the REACh and CLP regulations (regulation n ° 1272/2008 relating to the classification, labeling and packaging of substances and mixtures).

This project involved the control authorities of 16 Member States, including France, to check the conformity of products before they enter the European market (controls in ports, airports, etc.). The controlled products were of two types:

  • Chemical products: verification of compliance with labeling and packaging requirements for mixtures, in application of the CLP regulation,
  • Articles: verification of compliance with the restrictions defined in appendix XVII of the REACh regulation, by targeting some chemical substances such as cadmium, nickel, lead.

Overall, 23% of controlled imported products showed non-conformities with REACh or CLP. The report underlines that the controlled products were of multiple origin (37 countries identified), with a majority coming from China; China is also the first in terms of non-conformities.

The remainder of the CTC article presents the detailed results related to the chemical restrictions of Annex XVII of REACh.

Focus on articles

1225 checks were carried out by Member States to verify compliance with chemical restrictions: 17% of items checked were non-compliant. The European project targeted a few categories of articles concerned by 3 entries in Annex XVII:

  • Cadmium in metal parts of jewelry and plastics (entry n ° 23): 14% non-compliant rate;
  • Nickel in jewelry and metal parts of fashion items (entry n ° 27): 6%  non-compliant rate;
  • Lead in jewelry (entry n ° 63): 7% non-compliant rate.

Each Member State was free to control other restrictions defined in Annex XVII of REACh. About ten analyzes on chromium 6 in leather articles were carried out: 17% did not comply with the limit defined in entry n ° 47 of annex XVII of REACh. The investigation report also mentions the spot check of the restriction on azo dyes in leather and textile articles (entry n ° 43): no non-compliance was noted.


The investigation report lists several recommendations for improving the conformity of products entering the European market: the European Commission is therefore invited to establish systematic and harmonized controls for imported products, insofar as the rates of non-conformities observed are of the same order of magnitude as 3 years ago during a previous survey.

Link to the ECHA press release

Link to the investigation report


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