Your regular update for technical and industry information

Your regular update for technical and industry information

EU: ECHA published enforcement project results on REACH restriction and CLP


On 24 September 2020, the European Chemicals Agency (ECHA) published a report for the results of a pilot project1,2 conducted by ECHA’s Enforcement Forum3 on cooperation with customs in enforcement of REACH restrictions and CLP labelling. One in every four imported products were found to be non-compliant with REACH and CLP.

The pilot project was operated from March to November of 2019 and participated by 17 Member States (but only 16 reported results). The primary focus of this project was to check the compliance of imported goods and to prohibit the entrance of non-compliant products to the European market. The checks were carried out by national enforcement authorities and customs inspectors, and the majority of checks addressed the compliance of REACH restriction obligations, focusing on restrictions on cadmium, lead and nickel. While the checking of CLP compliance is mainly on simple check on labelling and packaging elements. 

Key findings of this project can be found below.

  • Twenty-three percent (23%) of inspected products are non-compliant with REACH and CLP (321 out of 1389).

    • 1225 products were checked for REACH restrictions. The non-compliance rate for restrictions is 17%;
    • 167 products were checked for CLP provisions. The non-compliance rate for CLP is 64%.
  • Majority (987 products) of checked products were originated from China and the majority of non-compliant products were also from China.
  • Most of checked products are jewelleries and metal articles (more than 1000 products), followed by a small number of plastic and leather products.
  • Besides restrictions on cadmium, lead and nickel, some products were also checked for other restrictions, i.e. asbestos, azo colourants, chromium VI, polycyclic aromatic hydrocarbons (PAHs) and phthalates. The highest non-compliance rate is cadmium restriction. Table 1 shows the number of products checked and non-compliant products for each restriction.
  • Most non-compliances for CLP were related to labelling requirements. The most common violation was the absence of the use of national language on the label, followed by the use of wrong or absent pictograms and signal words.
  • Twenty-one percent (21%) of all non-compliant products were not released for free circulation and were destroyed, re-exported or placed in temporary storage. The remaining non-compliant products were released for free circulation after corrective measures.
Table 1.
Restriction Number of products
Number of non-compliant
Cadmium 1118  161
Lead 1044 78
Nickel 622 36
Asbestos 48 13 (5 of 6 toys were non-compliant with phthalates restriction)
Azo colourants 10
Chromium VI 16
PAHs 1
Phthalates 6

Background information

The Enforcement Forum is an ECHA body which coordinates a network of authorities responsible for the enforcement of the REACH and CLP Regulations in the EU, Norway, Iceland and Liechtenstein. Please refer to the link of reference 3 below for the introduction of the Forum3. The Forum coordinates various enforcement projects including this. Please refer to the link of reference 4 if you are interested in the other projects handled by the Forum4


[1]  Report for the results of pilot project

[2]  ECHA Press Release - 1 in 4 imported products found to be non-compliant with REACH and CLP

[3]  Introduction of the ECHA Enforcement Forum

[4]  Forum enforcement projects


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