EU Enforcement Checks Reveal High Non-Compliance in Imported Chemicals and Consumer Products

On 10 December 2025, the European Chemicals Agency published the results of an EU-wide enforcement project under the Enforcement Forum. The project identified significant non-compliance with REACH requirements in imported substances, mixtures, and consumer products. These findings are based on the Forum REF-12 project, which focused on the registration, restriction, and authorisation obligations for imports entering the European Economic Area (EEA).

Background

The REF-12 project aimed to strengthen REACH enforcement at EU borders by improving cooperation between enforcement authorities and customs, and by developing more effective, risk-based targeting methods. The inspections focused on products where non-compliance was anticipated; therefore, the results do not reflect the overall compliance rate of all imports into the EEA.

Extensive EU-Wide Controls on Imports

Inspectors in 29 EEA countries carried out 2,603 targeted inspections of imported substances, mixtures, and articles. The inspections were conducted in close cooperation with customs authorities and focused on products considered at higher risk of non-compliance. Almost all non-compliant products identified before being released for free circulation were either denied entry to the EEA market or allowed entry only after corrective measures had been taken.

Registration Failures in Imported Mixtures

Checks on REACH registration obligations revealed a particularly high non-compliance for substances imported as part of mixtures.

• 32% of substances in mixtures lacked the required REACH registration.
• For substances imported on their own, registration was missing in 7% of cases.

The Enforcement Forum noted that many importers were not fully aware of their REACH obligations and, in some cases, were unaware of the substances present in the mixtures they were placing on the EU market.

Restricted Hazardous Substances Still Common in Consumer Goods

Inspectors also examined more than 1,300 imported mixtures and consumer products for compliance with REACH restrictions.

• 16% of the products checked contained restricted hazardous substances above the permitted limits.
• Most inspections targeted imported jewellery, with a particular focus on nickel, cadmium, and lead.
• Controls also covered toys, textiles, and footwear.

The results confirm persistent non-compliance in imported jewellery, especially with regard to nickel, and show little improvement compared to earlier enforcement projects.

Gaps Identified in Authorisation Compliance

Enforcement authorities also checked compliance with REACH authorisation requirements for imported substances of very high concern listed in Annex XIV. Out of the 21 relevant cases, authorisation was missing or had expired in four cases, highlighting the ongoing challenges of monitoring authorised substances at the import stage.

Strengthened Cooperation with Customs

The project demonstrated the importance of targeted sampling strategies and the systematic use of customs import data. Enhanced cooperation between customs and national REACH enforcement authorities was identified as a key factor in improving the detection of non-compliant imports and ensuring more efficient future controls.