EU: ECHA enforcement project results show non-compliance in imported products
December 2025 - Electrical & electronics, hardlines, softlines and toys and children's products
On 10 December 2025, the European Chemicals Agency (ECHA) published a report for the results of the enforcement project (REF-12)1,2 led by the ECHA’s Enforcement Forum.
This was an EU-wide enforcement project where 29 European Economic Area (EEA) countries performed 2603 controls to check imports for compliance with the REACH duties during 2024. The project results highlight significant non-compliance with REACH regulation among imported substances, mixtures and consumer products. The project results show the importance of a well-informed and well-designed sampling and targeting strategy for performing enforcement activities. The project also helped to raise awareness among the inspected companies, which should help them to comply with REACH in their future imports.
Key findings of the project results are below:
- Registration duties: The non-compliance rate for substances imported in mixtures is 32%, while for substances imported on their own is 7%.
- Restriction requirements: The overall non-compliance rate is 16% (214 out of 1329 products) - for articles is 17%, and for mixtures is 11%. Key findings include:
- Persistent non-compliance in jewellery (142 out of 780 articles): Heavy metals such as nickel, cadmium and lead remain prevalent, and the overall picture of non-compliance has not improved;
- Targeted controls on toys, textiles, and other consumer goods also identified breaches of REACH restriction requirements, such as phthalates in plastic products, formaldehyde in footwear;
- The forum suggests member states to continue to focus on the enforcement of REACH restrictions, in particular, imported jewellery items.
- Authorisation duties: Among 21 checks on imported Substances of Very High Concern (SVHCs) subject to REACH authorisation, the authorisation was missing or expired in 4 cases.
For non-compliant products, enforcement measures were imposed by the enforcement authorities. The most common enforcement measure by the national enforcement authorities was the issuance of written advice (in 37 % of the cases where breaches were noticed). The other enforcement measures included destruction of the products, public announcements, verbal advice, etc.
References:
[1] Reports for REF-12[2] ECHA press release - Hazardous chemicals found in many consumer products
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