REACH Enforcement: key findings from the REF-12 project

On 10 December 2025, the REF-12 Forum report was published, outlining the results of an extensive enforcement initiative carried out in 2024 by the European Chemicals Agency (ECHA) to verify compliance of imported products with the REACH Regulation.

The report specifically analyses the level of compliance with REACH obligations on registration, restriction and authorisation.

The REF-12 project, promoted by the Forum for the Enforcement of REACH, aimed to strengthen controls on substances, mixtures and articles imported into the European Market from outside countries.

The initiative focused on the harmonised enforcement of REACH obligations related to registration, restriction and authorisation, while also enhancing cooperation between national enforcement authorities (NEAs) and customs authorities.

In addition, the project proposed possible working methods that national competent authorities could adopt to cooperate more effectively with customs authorities.

The project involved 25 EU Member States and EEA countries and resulted in more than 2,600 inspections, carried out both at the EU external borders and after products had been placed on the market. This “dual track” strategy made it possible to identify non-compliant products both before and after their entry onto the European market.

The results show that the most effective models for detecting non-compliance are those based on the analysis of customs data by REACH authorities and on joint inspections. In particular, the model in which customs authorities provide historical import data to NEAs was widely used for registration checks, while joint inspections proved highly effective in identifying violations before products were placed on the market.

With regard to the products inspected, enforcement activities mainly focused on:

• jewellery
• detergents
• cosmetics
• organic and inorganic chemical substances
• toys

Overall, jewellery was the most frequently inspected product category, mainly due to the risk of the presence of restricted heavy metals. The inspected products originated from 69 countries, with a strong prevalence of imports from China, followed by the United Kingdom, Turkey, India and the United States.

With respect to the import of substances and mixtures, the results highlight significant shortcomings in REACH registration compliance. Considering only substances actually subject to registration obligations, the overall non-compliance rate was 18%. This figure is strongly influenced by substances imported as components of mixtures, for which non-compliance reached 32%, suggesting a lack of awareness or inadequate management of REACH obligations by EU importers. Substances imported “as such” showed a lower level of non-compliance.

When analysing countries of origin, the highest rates of non-compliance with registration requirements were found for substances originating from Turkey, the United Kingdom, India, and China.

For the United Kingdom, the report highlights that the high level of non-compliance is likely linked to the effects of Brexit, which rendered many previously submitted registrations invalid.

As regards restrictions, the project confirms persistent non-compliance in the jewellery sector, particularly with respect to heavy metals such as lead, cadmium and nickel. Despite improvements compared to previous projects for lead and cadmium, non-compliance with nickel restrictions is increasing.

The findings related to asbestos are also a cause for concern, with a non-compliance rate higher than expected, especially in components of complex articles.

With regard to authorisations, the project underlines the importance of targeted controls on substances with a recent “sunset date” and the need for timely updates of TARIC codes to effectively support enforcement activities.

Overall, REF-12 demonstrated that structured cooperation between REACH authorities and customs is essential to prevent non-compliant products from entering the European market, to protect human health and the environment, and to ensure fair competition among economic operators. The results and recommendations of the project provide useful operational guidance for both authorities and importing companies, particularly to strengthen REACH compliance management along the international supply chain.