REACH — Registration, Evaluation, Authorisation and Restriction of Chemicals — is the EU's primary chemical regulation framework. It applies to any substance manufactured in, or imported into, the EU in quantities of one tonne per year or more. Indian companies that export chemicals to European buyers are effectively exporting into a REACH-regulated supply chain, even if they never interact with the regulation directly.
The key mechanism is the Only Representative (OR). When an Indian company supplies chemicals to a European importer, the EU importer is typically responsible for REACH registration. However, if the Indian supplier has appointed an EU-based Only Representative, the OR takes on that responsibility. As an Indian exporter, understanding whether your European customer has an OR arrangement — and who bears the registration obligation — is essential before entering a supply agreement.
For Indian exporters, practical REACH requirements fall into two categories. The first is substance registration: for high-volume products above 100 MT/year into the EU, your OR must ensure the substance is registered in the ECHA database. The second is downstream communication: SDS documents must comply with EU GHS requirements, and substances of very high concern (SVHC) must be disclosed even at trace levels above 0.1% w/w.
The most common compliance gap among Indian suppliers is SDS quality. A domestic-market SDS prepared under Indian MSIHC rules will not satisfy REACH Article 31 requirements. If you are shipping to EU buyers, your SDS must be revised to EU GHS format (Regulation 1272/2008) with all sixteen sections completed accurately and in the customer's official language.
The practical first step: obtain a current SVHC candidate list from ECHA, cross-check your product formulations, and engage an EU-based REACH consultant if your export volumes to Europe exceed 1 MT per year for any single substance. The cost of proactive compliance is a fraction of the cost of a shipment rejected at Rotterdam.