ECHA REF-16 Enforcement Project to Target REACH Restriction Compliance in Products

ECHA REF-16: Focus on REACH Restrictions and Online Sales

Under the upcoming REF-16 project, inspectors will check whether products or mixtures placed on the EU market comply with restriction requirements under EU chemicals legislation, especially the restrictions listed in Annex XVII to the REACH Regulation.

The inspections are expected to verify whether restricted hazardous substances in products remain below the applicable legal limits. This may affect a wide range of products and mixtures, depending on their composition, use and product category.

A key feature of REF-16 is the inclusion of online sales. ECHA and national enforcement authorities are expected to pay closer attention to products sold through:

The Forum will also work with the European Commission and Member State authorities to explore how findings from online sales inspections may support the enforcement of the Digital Services Act, particularly where online platforms are used to market non-compliant products.

Other ECHA Enforcement Actions: Tattoo Inks, CLP Dossier Updates and Biocides

In addition to REF-16, ECHA's Enforcement Forum and its biocides subgroup have announced several targeted actions covering other high-priority compliance areas.

Tattoo Inks and Permanent Make-up

Inspectors will run a pilot project on tattoo inks and permanent make-up products. The project will check whether these products comply with restrictions on hazardous substances and whether labels meet applicable requirements.

The inspections are planned for 2027, with the report expected in 2028.

This project is relevant for manufacturers, importers, brand owners and distributors of tattoo inks and permanent make-up products sold in the EU.

REI-1: Rapid Enforcement on CLP Dossier Updates

ECHA's first Rapid Enforcement Initiative, REI-1, will focus on companies that fail to update their registration dossiers following changes to harmonised classification and labelling.

Under the EU CLP Regulation, harmonised classification and labelling helps ensure consistent hazard communication across the EU. When a substance receives or changes its harmonised classification, registrants may need to update their REACH registration dossiers accordingly.

The REI-1 initiative indicates that Member State authorities may carry out more targeted and faster follow-up actions on cases identified by ECHA.

BEF-4: Online Sales of Biocidal Products

The next biocides enforcement project, BEF-4, will focus on the online sale of biocidal products and cross-border cooperation among enforcement authorities.

Inspectors are expected to check whether online biocidal products, such as wood preservatives, rodenticides or insecticides:

• provide the required information to customers;

• hold valid product authorisations;

• contain approved active substances;

• comply with applicable requirements under the EU Biocidal Products Regulation.

BEF-4 inspections are planned for 2028, with the report expected in 2029.

Why This Matters for Companies Supplying the EU Market

The upcoming enforcement actions show that EU authorities are moving from broad regulatory implementation to more targeted market surveillance. The focus is likely to be on products with higher non-compliance risk, especially imported products and products sold online.

For companies outside the EU, this may create practical compliance challenges. Even if a product is manufactured outside Europe, it may still be checked once it is placed on the EU market by an importer, distributor, marketplace seller or downstream business partner.

Key risk areas include:

• restricted substances in products or mixtures exceeding applicable limits;

• incomplete or outdated supplier declarations;

• product listings that do not reflect required hazard or authorisation information;

• labels inconsistent with SDSs, dossiers or online product information;

• REACH registration dossiers not updated after changes to harmonised classification and labelling;

• biocidal products sold online without valid authorisation or approved active substances.

Companies should treat the enforcement schedule as an opportunity to review their EU product compliance systems before inspections start.

Impact & Actionable Advice for Global Companies

Companies exporting to, manufacturing in, or distributing within the EU should review product-level compliance, online sales information and regulatory documentation in advance of the 2027–2029 enforcement cycle.

1. Review REACH Restriction Compliance

   Companies should screen products and mixtures against the relevant entries in REACH Annex XVII.

   Recommended actions include:

   Companies should avoid relying solely on general supplier statements. For higher-risk products, technical documentation, analytical testing or full material disclosure may be needed.

• identifying restricted substances that may be present in products, components or mixtures;

• checking applicable concentration limits and product-specific restriction conditions;

• reviewing supplier declarations, test reports and formulation data;

• assessing higher-risk product groups, such as consumer goods, coatings, plastic products, textiles, adhesives, inks and chemical mixtures;

• maintaining evidence that restricted substances are below applicable legal limits.

2. Strengthen Online Sales Compliance

   As online sales become a specific inspection focus, companies should review whether product information displayed online is aligned with EU chemical compliance requirements.

   Recommended actions include:

   This is particularly important for companies selling through multiple online platforms, where inconsistent product information can increase enforcement risk.

• checking whether online product descriptions match approved uses and restrictions;

• verifying that required hazard, safety or authorisation information is not omitted;

• aligning website, marketplace and distributor listings with product labels and SDSs;

• confirming whether online sales of biocidal products meet BPR authorisation and information requirements;

• establishing internal review procedures before launching EU online listings.

3. Update REACH Registration Dossiers When Required

   Companies with REACH registration obligations should monitor changes to harmonised classification and labelling and update their registration dossiers when required.

   Recommended actions include:

   The REI-1 initiative suggests that late or missing dossier updates may become a more visible enforcement target.

• monitoring updates to CLP Annex VI harmonised classifications;

• reviewing whether the change affects registered substances;

• updating IUCLID dossiers where necessary;

• ensuring SDSs and labels remain consistent with updated classification and labelling;

• keeping records of internal review and update decisions.

4. Verify Biocidal Product Authorisation and Online Information

   Companies selling biocidal products in the EU should verify product authorisation status and online sales claims before the BEF-4 inspections begin.

   Recommended actions include:

   This is especially relevant for wood preservatives, rodenticides, insecticides and other biocidal products commonly sold through online channels.

• confirming that each biocidal product has valid authorisation for the relevant market;

• verifying that active substances are approved for the relevant product type;

• reviewing online claims, directions for use and customer-facing information;

• checking whether cross-border online sales create additional national compliance issues;

• aligning labels, product summaries and online sales pages.

5. Build an Inspection-ready Compliance File

   Companies should prepare documentation that can support product compliance during an inspection or customer audit.

   Useful records may include:

   Maintaining a clear compliance file can help companies respond more efficiently to EU importers, distributors, online platforms and enforcement authorities.

• formulation and composition data;

• restricted substance screening records;

• supplier declarations and testing reports;

• SDSs and labels;

• REACH registration and dossier update records;

• CLP classification and labelling review records;

• biocidal product authorisations;

• screenshots or archives of online product listings;

• internal compliance review logs.

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