Does your Indian chemical product need REACH registration for the UK or EU?
A plain-English guide to the most commonly exported Indian chemical categories — with HS codes, REACH status, and what you need to do. Can't find yours? Send us a WhatsApp.
What triggers REACH?
REACH applies to chemical substances placed on the UK or EU market — either on their own or as part of a mixture. If you manufacture a chemical in India and export it to a UK or EU buyer, REACH applies to you (or your OR).
The 1 tonne threshold
Registration is required if you export 1 tonne or more per year of a substance into the UK or EU. Below this, you may still have CLP classification and SDS obligations — but no full registration is needed.
UK REACH vs EU REACH
Since Brexit, these are two separate regulations. UK REACH is run by the HSE; EU REACH by ECHA. Selling into both markets may need separate OR appointments and registrations.
Common Indian export categories — REACH status at a glance
Use this table as a starting point. The actual requirements depend on the specific CAS number, tonnage, and market. Not sure? Ask us for a free check.
| Product category | Typical HS codes (Chapter) | UK REACH status | EU REACH status | Key watch-outs |
|---|---|---|---|---|
| Reactive & Disperse Dyes e.g. Reactive Red, Disperse Blue, Direct dyes | 3204.11, 3204.12, 3204.13, 3204.19 | OR required | OR required | Many dye molecules are individual substances with separate CAS numbers — each needs assessment. SVHC concerns for some azo dyes. |
| Organic Pigments e.g. Pigment Yellow, Phthalocyanine Blue, Pigment Red | 3204.17, 3206.49 | REACH reg. required | REACH reg. required | High-volume pigments usually already registered. Check if your specific CAS is in an existing SIEF — may be able to join rather than register fresh. |
| Surfactants & Detergent Intermediates e.g. LAS, AES, APG, betaines, amphoteric surfactants | 3402.11–3402.90 | REACH reg. required | REACH reg. required | Common surfactant types usually have existing registrations. Key is confirming your buyer's importer is covered, or appointing an OR. |
| Textile Auxiliaries & Finishing Agents e.g. softeners, fixatives, optical brighteners, sizing agents | 3809.91, 3809.92, 3809.93 | OR required | OR required | Often mixtures — each individual substance in the mixture must be assessed. Some contain SVHC substances requiring downstream user notification. |
| Agrochemical Intermediates & Active Ingredients e.g. herbicide intermediates, fungicide APIs, pyrethroid precursors | 2921.XX, 2922.XX, 2926.XX, 2930.XX, 2933.XX | Check needed | Check needed | Biocidal products have their own regulation (BPR / UK BPR) in addition to REACH. Plant protection products (PPP) may be exempt from REACH but not BPR. Specialist advice needed. |
| Pharmaceutical & API Intermediates e.g. API building blocks, fine chemical intermediates | 2934.XX, 2935.XX, 2936.XX, 2937.XX | Check needed | Check needed | Medicinal products are generally exempt from REACH, but chemical intermediates used in their manufacture are not. The key is how the substance is used by your UK/EU buyer. |
| Aroma Chemicals & Essential Oils e.g. linalool, citronellol, geraniol, isolongifolene | 2906.XX, 2912.XX, 2914.XX, 3301.XX | OR required | OR required | Individual aroma chemicals usually have their own CAS and registration status. Natural complex substances (essential oils) have specific REACH guidance — check each one. |
| Rubber Chemicals & Polymer Additives e.g. accelerators, antioxidants, crosslinkers, plasticisers | 2925.XX, 2933.XX, 3812.XX | REACH reg. required | REACH reg. required | Some rubber chemicals are on SVHC lists (e.g. certain phthalates, CBS). Check for authorisation requirements as well as registration. |
| Paints, Coatings & Resin Intermediates e.g. alkyd resins, epoxy intermediates, pigment pastes | 3208.XX, 3209.XX, 2910.XX, 2915.XX | REACH reg. required | REACH reg. required | Polymers themselves are generally exempt, but polymer monomers and reactive intermediates are not. Formulated paints and coatings are mixtures — constituent substances must each be compliant. |
| Industrial Solvents & Process Chemicals e.g. MEK, toluene, acetonitrile, DMF, NMP | 2901.XX–2915.XX | REACH reg. required | REACH reg. required | Most bulk solvents are already registered under ECHA/HSE. If importing at high tonnage, ensure you're covered under an existing registration or appoint an OR. |
| Water Treatment & Specialty Chemicals e.g. coagulants, flocculants, scale inhibitors, biocides | 2842.XX, 3824.XX | Check needed | Check needed | Biocidal active substances used in water treatment are regulated under BPR in addition to REACH. Requires specialist review. |
| Construction Chemicals e.g. admixtures, waterproofing agents, concrete additives | 3824.40, 3824.90, 2530.XX | OR required | OR required | Often supplied as mixtures. Article 33 SVHC disclosure obligations may apply if concentrations exceed 0.1% w/w. Check individual substance SVHC status. |
| Cosmetic Ingredients (INCI listed) e.g. emollients, preservatives, emulsifiers, active botanicals | 3304.XX, 3305.XX, 3306.XX, 3307.XX | Often exempt | Often exempt | Finished cosmetic products are regulated under the UK Cosmetics Regulation / EU Cosmetics Regulation, not REACH. However, raw material suppliers to cosmetic manufacturers do have REACH obligations. Check your supply chain role. |
How much are you exporting? It changes what you need to do
REACH registration requirements — and the associated costs — increase with the annual tonnage you export. Here's a plain-English summary.
Below 1 tonne
Registration is not required. However, CLP classification and Safety Data Sheets may still be needed. Also check if your substance appears on any SVHC or restriction lists.
Action: SDS + CLP check1 to 10 tonnes
Registration required. At this band, hazard data requirements are lighter and a Chemical Safety Report (CSR) is generally not required. Often the most cost-effective band.
Action: Registration dossier10 to 100 tonnes
Registration required. Chemical Safety Report (CSR) required, along with expanded hazard data. More data studies may be needed if existing data is limited.
Action: Full dossier + CSR100 tonnes and above
Full registration with extensive hazard datasets, CSR, and exposure scenario development. Costs are significant — but so are the commercial benefits of being fully compliant at scale.
Action: Full dossier + CSR + ESTonnage is calculated per registrant per year, not total market volume. If you appoint an OR, the OR registers on your behalf and the tonnage is your export volume to the UK or EU.
Common questions from Indian exporters
If you are exporting a chemical substance on its own or as part of a mixture to the UK in quantities of 1 tonne or more per year, you will generally need it to be registered under UK REACH. As a non-UK manufacturer, you can't register directly — but you can appoint an Only Representative (OR) based in the UK to do it on your behalf.
Below 1 tonne/year, registration isn't required — but you'll still need compliant Safety Data Sheets and CLP classification.
Since Brexit (31 December 2020), the UK has its own version of REACH — called UK REACH — administered by the Health and Safety Executive (HSE). EU REACH covers the 27 EU member states and is administered by ECHA (European Chemicals Agency) in Helsinki.
EU REACH registrations no longer cover sales into Great Britain. If you want to sell into both markets, you will likely need separate compliance steps for each — and potentially two separate OR appointments.
An Only Representative (OR) is a company established in the UK or EU that takes on REACH registration responsibilities on behalf of a non-UK/non-EU manufacturer. Under REACH, the company responsible for registration must be in the UK or EU — so as an Indian exporter, you need either your UK importer to register, or an OR to do it for you.
Appointing an OR is usually the better option because it:
- Removes the registration burden from your UK/EU importer
- Gives you more control over your compliance
- Lets you sell to multiple importers in the same market under a single registration
- Protects your formulation confidentiality
Reychem can act as your OR for UK REACH, EU REACH, or both.
Registration is required when you (or your OR) exports 1 tonne or more of a substance per year into the UK or EU. This is calculated per substance, per registrant, per year — not total market volume.
So if you export 800 kg of substance A to the UK, and 400 kg to Germany, each of those is below 1 tonne and wouldn't individually trigger registration — though you should still have compliant SDS documents for both shipments.
If the combined volume to the UK, or combined volume to EU countries, exceeds 1 tonne per year, registration will be triggered for the relevant market.
DUIN stands for Downstream User Identification Number. Under UK REACH, when an Only Representative registers a substance, they receive a registration number. Your UK importer is then identified as a downstream user and receives a DUIN — confirming they're covered under the OR's registration.
When your buyer asks for a DUIN, they're asking for evidence that the substance is registered and that they're covered by that registration. If Reychem is your OR, we handle this as part of our service and can provide the relevant documentation to your buyer.
A full REACH registration dossier can take anywhere from 3 months to over 12 months depending on data availability, whether new studies are needed, and the specific substance.
However, if your need is urgent, the first thing to do is check whether your substance is already registered by another company. If so, you may be able to access an existing registration through a Letter of Access (LoA) arrangement — which can be significantly faster and cheaper than a fresh registration.
Only Representative appointment is usually quicker — we can often have an OR agreement in place within days. Contact us to discuss your specific timeline and we'll be straight with you about what's realistic.
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Send us your product name, CAS number if you have it, and roughly how much you want to export. We'll come back to you with a clear answer — free, no obligation.