Industries Cosmetics & Beauty
REACH for cosmetics: your SVHC obligations when you don't manufacture
You are still in REACH without a factory: distributor, importer, or downstream user. The Candidate List holds 253 substances.
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On February 4, 2026, the European Chemicals Agency (ECHA) added n-hexane and BPAF to the Candidate List, which now counts 253 substances of very high concern (SVHC). If your cosmetics brand buys its formulas from a contract manufacturer, that update concerns you, even though you have never owned a mixing tank. REACH, the European regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals, does not stop at the factory gate: it assigns a role to every actor in the chain, and yours depends on where your products come from.
Your REACH role is decided at the border, not at the plant
REACH distinguishes four roles: manufacturer, importer, downstream user, and distributor. A brand with no production site holds one of the last three, and often several at once across its ranges.
Your contract manufacturer is in the EU and you resell under your brand. You are a distributor: you store and place on the market without transforming anything. Your obligations come down to moving information in both directions, safety information toward your customers, and your customers' questions back to the manufacturer.
You import finished products from outside the EU. You become the importer of a mixture, required to register every substance you bring in above one metric ton per year, unless the foreign manufacturer has appointed an only representative (Article 8) who takes on that duty. In that case you are treated as a downstream user, on the condition that you are covered by name.
You dilute, blend, fill, or repackage in the EU. You are a downstream user, exactly as your contract manufacturer is for the formulas it produces.
The responsible person role under the Cosmetics Regulation (EC) No 1223/2009 is a separate function. Holding it settles none of these obligations, and none of them settles it.
What the Cosmetics Regulation does not cover for you
Regulation (EC) No 1223/2009 governs the safety of the finished product for human health: its annexes of banned and restricted substances, the product safety report, the responsible person. REACH steps back where that text applies, and nowhere else. That still leaves four things on your desk.
Ingredient registration. Substances used in cosmetics are registered like any others. Only the consumer-exposure part of the assessment is taken over by the Cosmetics Regulation (Article 14(5) of REACH).
The environmental restrictions of Annex XVII. The microplastics restriction (Regulation (EU) 2023/2055) is the most concrete example: exfoliating microbeads banned since October 17, 2023, rinse-off products by October 17, 2027, leave-on products by October 17, 2029, and makeup, lip, and nail products by October 17, 2035.
Authorization, when the environment is at stake. The cosmetics exemption in Article 56(5) only applies to substances placed on Annex XIV for human-health hazards. A listing on environmental grounds applies to your formulas in full.
Your packaging. A bottle, a jar, or a pump is an article under REACH. Above 0.1% by weight of a Candidate List substance, Article 33 requires you to inform your business customers unprompted and any consumer within 45 days, and the SCIP database (the EU database of articles containing SVHCs) has expected a notification since January 2021.
Good to know: a bottle pump is an assembly of articles. The 0.1% threshold applies to each part, spring included, not to the bottle as a whole.
On the other hand, no safety data sheet (SDS) is due for a finished cosmetic product: Article 2(6) exempts it from Title IV of REACH. SDSs remain due for raw materials.
The declarations to collect, supplier by supplier
| Supplier | What you ask for | What it must contain |
|---|---|---|
| EU contract manufacturer | REACH status of your formulas | Product references, Candidate List status with the version (253 entries as of February 4, 2026), microplastics timeline per category |
| Non-EU manufacturer | Only-representative coverage | Appointment letter, your legal entity named, substances and tonnages covered |
| Packaging supplier | Article 33 declaration | Per reference, substance and concentration where relevant, SCIP dossier number |
| Raw-material supplier (if you fill) | Up-to-date SDS | Registration numbers, exposure scenarios covering your use; you have 12 months to apply the conditions |
Date every answer and record the Candidate List version it refers to. A declaration issued before February 4, 2026 knows nothing about n-hexane or BPAF.
The declarations that prove nothing
Every supplier folder I open at a cosmetics brand contains at least one of the following documents, filed as proof.
The "REACH certificate." It does not exist. ECHA issues no certificate of any kind, so the document can only be a voluntary statement, to be read as one.
The blanket letter. "All our products comply with REACH," with no reference, no substance, and no list version, covers nothing verifiable.
The cosmetics file presented as REACH proof. A safety report under Regulation 1223/2009 demonstrates the safety of the finished product. It says nothing about substance registration or about your packaging. The two regulations are not interchangeable.
The registration number without your name. A non-EU supplier waving its only representative's registration number covers you only if the written confirmation names your company and your volumes.
The frozen declaration. The Candidate List grows roughly twice a year. An attestation from 2024 answers to a list that no longer exists.
Start by writing down your map: for each range, where the product comes from, who formulated it, who imports it. That one-page table fixes your REACH role per reference, and with it the exact declaration to request from each supplier. Do it before the next Candidate List update: there are about two per year.
FAQ
Our contract manufacturer is in the EU. Do we still have REACH obligations?
Yes, but light ones. As a distributor you must pass safety information down to your customers and their questions back up the chain. You also remain the supplier of your packaging, so Article 33 applies to you if a component contains a Candidate List substance above 0.1% by weight. The responsible person role under the Cosmetics Regulation is separate and remains yours.
We import finished products from outside the EU. Do we have to register the substances?
Yes, for every substance imported above one metric ton per year, unless the foreign manufacturer has appointed an only representative under Article 8 of REACH. In that case ask for written confirmation that names your legal entity and covers your volumes. Without it, the registration duty is yours.
Does the Candidate List concern our formulas or our packaging?
Both, in different ways. Packaging components are articles, so a Candidate List substance above 0.1% by weight of a component triggers Article 33 communication and a SCIP notification. Formulas are mixtures, so Article 33 does not apply to them, but a listing on environmental grounds can pull an ingredient toward authorization, and customers increasingly ask about Candidate List content in formulas.
How many substances are on the Candidate List?
253 since February 4, 2026, when n-hexane and BPAF were added. The list is updated roughly twice a year, which is why every supplier declaration should record the version of the list it refers to.
