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1 in 4 imported products found to be non-compliant with REACH and CLP


A pilot project by ECHA’s Enforcement Forum examining imports of products into the EU has found that 23 % of inspected products were non-compliant with REACH and CLP. Some imports contained illegal amounts of hazardous substances that are restricted in the EU, while others had incorrect hazard labelling – which could compromise their safe use and put citizens’ health at risk if they enter the market.

Helsinki, 24 September 2020 – National enforcement authorities and customs inspectors in 16 Member States checked almost 1 400 products, with more than 300 (23 %) found to be non-compliant with certain obligations under REACH and the Classification, Labelling and Packaging (CLP) regulations. The products were checked at strategic entry points in these countries, such as airports and harbours but also at inland customs offices.

The majority of checks addressed compliance with REACH restriction obligations, focusing on the presence of the restricted substances cadmium, lead and nickel in articles. Of the 1 225 checks for restricted substances, 17 % of the products had amounts of the restricted substances above the required limit. This rate is similar to those reported in the Forum’s previous project on restrictions (REF-4) conducted in 2016. The highest rate of non-compliance was for cadmium detected in jewellery.

The majority of the products were checked for restriction obligations (79 %) and those found to be non-compliant (74 %) mostly came from China, as well as from the United Arab Emirates, India, Thailand, North Macedonia and Madagascar. Importers of articles containing chemical substances must ensure that products placed on the EU market are compliant with REACH obligations.

These findings indicate that a significant number of imported products are in breach of REACH restictions and would put the health of those buying the products at risk if the products entered the market.

For CLP, 167 products were checked and 64 % were found to be non-compliant. The majority of the non-compliances were related to labelling requirements, most commonly a lack of national language, and lack of or use of incorrect pictograms and signal words on the hazard label.

The results show that importers need to intensify their efforts to supply safe products which are compliant with REACH and CLP. They also show there is a continued need for targeted enforcement on these specific restrictions and more stringent enforcement of REACH and CLP at European points of entrance.

One of the objectives of this project was to assess how cooperation between REACH/CLP enforcement and customs authorities worked in practice. The results indicate that there is well functioning cooperation between participating authorities and that the most frequent method of working during the project were joint checks performed by both customs and REACH/CLP inspectors.


The Forum for Exchange of Information on Enforcement (Forum) is a network of authorities responsible for the enforcement of the REACH, CLP, BPR, PIC and POP regulations in the EU, Norway, Iceland and Liechtenstein.

The pilot project examined cooperation models with customs authorities, and checked the compliance of imported goods while under customs supervision and before they enter the European market.

The project looked at various products that fall under three REACH restriction entries for articles and jewellery (entries 23, 27 and 63 of Annex XVII) and the labelling and packaging of substances and mixtures under CLP.