How do you answer a REACH statement of compliance request?

This answer covers business customers asking a chemical supplier about EU REACH. It does not cover UK REACH, which keeps its own Candidate List (HSE, 2026), or the format of a standing declaration document. A reply states facts about your product; whether the customer's own article or process complies stays with the customer.

What do you need before answering a REACH compliance request?

Before answering a REACH compliance request, you need the request itself, the exact product it concerns, the current safety data sheet with its revision date, and the dated list versions you will check against. Collect these before drafting a single answer.

• The request, kept whole, including any customer form or questionnaire version.

• The product identity: trade name, product code and, for a mixture, the formulation version the customer buys.

• Your own records: formulation records and the REACH statements your upstream suppliers sent, each with its date.

• The safety data sheet (SDS), technical data sheet (TDS) and certificate of analysis (CoA) for that product, each with its revision or lot date. The SDS format in Annex II as amended by Commission Regulation (EU) 2020/878 applies from 1 January 2021 (Commission Regulation (EU) 2020/878, 2020).

• The ECHA Candidate List as published on the day you check, with that date written down. The 4 February 2026 update, for example, added n-hexane and bisphenol AF and its salts (EU Transition Pathways, 2026).

• The name of the person who will sign the reply.

Allow time. The WKO standard questionnaire for REACH supply chain communication noted that information often has to come from the supplier's own suppliers and called a span of one month realistic for its questions, adding that complex products such as mixtures may need more (WKO, 2007). That figure dates from 2007 and refers to that questionnaire, so treat it as a planning guide, not a rule.

How do you split a customer's REACH request into answerable items?

You split a customer's REACH request into answerable items by giving every question its own number and rewriting each one as a single fact you can confirm or deny. A sentence such as "confirm your product is REACH compliant" holds several separate questions, and each needs its own evidence.

1. Copy the request and number every question in the order the customer asked it.

2. Split compound questions. "Registered and SVHC-free" becomes two items: registration status and Candidate List content.

3. Name the REACH topic of each item: registration, Candidate List substances, Annex XIV authorisation, Annex XVII restriction, or SDS content.

4. Name the role you answer in: manufacturer, importer, downstream user or distributor. The role decides which records you hold.

5. Mark items that are not about REACH, such as RoHS or conflict minerals, and answer them separately or say they are outside the reply.

6. Restate any item that asks for a conformity verdict on the customer's product as a factual item about your product, such as "Candidate List substances present at or above 0.1 % by weight in the mixture as supplied" (REACH Article 31(3), consolidated 2026).

Keep the numbering in the final reply, so the customer can match each answer to the question it closes.

Which evidence answers each REACH item: your records, the SDS, the CoA or the Candidate List?

The evidence for each REACH item comes in a fixed order: your own records first, then the SDS, TDS and CoA, then the public ECHA lists with the version you checked. The order matters because your formulation records know what went into the product, while public lists only tell you which substances are regulated. The table below decides which document answers which kind of item.

A TDS gives typical values, not guaranteed limits, so it cannot confirm that a substance is absent; use it only to describe the product. The Candidate List row is easy to answer from the SDS alone, which is not enough. Read the formulation and upstream statements first, then confirm that SDS section 3 lists the same substances, because Annex II, point 3.2.1, sets which substances section 3 of a classified mixture must show, including Candidate List substances at 0.1 % or more where they are listed for reasons other than the classification hazards (REACH Annex II, 3.2.1, consolidated 2026).

How much composition can a REACH reply disclose beyond the safety data sheet?

A REACH reply can disclose what the safety data sheet already discloses without further approval, and anything beyond it is a business decision for the company, not a REACH requirement. Annex II lets a mixture's composition appear in section 3 as "exact percentages in descending order by mass or volume, if technically possible" or as ranges (REACH Annex II, 3.2, consolidated 2026).

Use the SDS as your disclosure boundary. If section 3 gives a range, give the same range. If section 3 uses an alternative chemical name permitted under Article 24 of the CLP Regulation, use the same name in the reply (REACH Annex II, 3.2, consolidated 2026). Answering a Candidate List item does not need the full formula: a statement that no Candidate List substance is present at or above 0.1 % by weight, with the list date, answers it.

When the customer asks for more, such as exact percentages or the full ingredient list, send the request to the person who owns confidential information in your company. That person may offer a confidentiality agreement or a direct disclosure to the customer's authority. The 2007 WKO questionnaire was built to exchange information "without overly specific details on uses or product composition" (WKO, 2007). Do not invent a percentage to satisfy a form.

What do you write when you cannot confirm a REACH item yet?

When you cannot confirm a REACH item yet, you write that it is unconfirmed, how you will confirm it, and the date you expect to reply, instead of a guess. A guessed "yes" becomes a false statement the customer may pass down their own supply chain.

Write each unconfirmed item in three parts:

1. Status: "Not yet confirmed."

2. Route: the record you are waiting for, such as an upstream supplier's Candidate List statement, a registration confirmation or a test result.

3. Date: the date you expect to send the answer.

The WKO questionnaire builds this option into its form with the answer "too early to decide. Reply probably by" followed by an expected date of reply (WKO, 2007). An illustrative item reads: "Item 4, Candidate List content: not yet confirmed; awaiting the upstream supplier's statement against the Candidate List as published on the date of their check; expected reply by the date stated."

Answer the items you can confirm now and send them. Holding the whole reply for one open item delays every answer the customer could already use. When the open item closes, send the update with the same item number, so the customer's record stays linked to the original request.

How do you check a REACH reply before it goes out?

You check a REACH reply before it goes out by testing each numbered item against five checks: answered, evidence dated, Candidate List date stated, composition within the SDS, and open items given a route and date. The table below decides whether an item can be sent.

The Candidate List row needs the most care, because an answer without a list date cannot show which entries were checked. A one-line reply such as "our product is REACH compliant" fails every row at once, since it answers no numbered item and names no evidence. Have the signer read the final numbered list against the original request before release. Remove any sentence that declares the customer's own product compliant. Send the reply to a regulatory specialist first when an item involves an authorisation, a restriction with conditions, or a jurisdiction outside the EU. Lubinpla's technical inquiry reply works from your own records and data room files such as the SDS, TDS and CoA, then public sources, marks any item it cannot support as unconfirmed, and returns one cited reply for your review before it goes out.