Forum REACH-EN-FORCE 3 - Phase 1 Project Report : inspection and enforcement of compliance with registration obligations by manufacturers, importers and only representatives in close cooperation with customs.
Date: 2015-05-06
Institutions: European Chemicals Agency
Subjects: chemical product, customs regulations, environmental risk prevention, exchange of information, industrial chemistry, industrial manufacturing, industrial policy, production control, regulation (EU), report, technical regulations

F o r u m   F o r   E x c h a n g e   O f   
I n f o r m a t i o n   O n   E n f o r c e m e n t

Forum REACH-EN-FORCE 3 
– Phase 1 Project Report

Inspection and enforcement of compliance with  
registration obligations by manufacturers, importers and  
only representatives in close cooperation with customs

Disclaimer
This document aims to assist users in complying with their obligations under the REACH and CLP Regulations. 
However, users are reminded that the text of the REACH and CLP Regulations are the only authentic legal 
references and that the information in this document does not constitute legal advice. Usage of the information 
remains under the sole responsibility of the user. The European Chemicals Agency does not accept any liability 
with regard to the use that may be made of the information contained in this document.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report
Inspection and enforcement of compliance with registration obligations by manufacturers, importers and 
only representatives in close cooperation with customs

ECHA-14-R-15-EN 

Reference:  
Cat. number:   ED-02-14-624-EN-N 
978-92-9244-670-3 
ISBN:  
10.2823/35368 
DOI:  
June 2014 
Date:  
English
Language:  

© European Chemicals Agency, 2014

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Table of Contents

1.  EXECUTIVE SUMMARY 

2.  BACKGROUND 

2.1  Background of the project 
2.2  Legislative background 

3.  RESULTS OF THE PROJECT 

3.1  Participation and number of company inspections 
3.2  Role of inspected companies under REACH and their size 
3.3  Types of the inspected companies according to their economic activities 
3.4 

Inspected companies’ total number of manufactured  

  and imported substances and mixtures  

3.5  Registration obligations 
3.6  Results of the company inspections 
3.7  Non-compliance issues and measures taken 

4.  OVERALL CONCLUSIONS 

5.  RECOMMENDATIONS 

6.  ANNEXES 

 Annex 1: List of the relevant Community legal acts 

6.1 
6.2  Annex 2: Supplementary figures and tables  
6.3  Annex 3: Glossary  

4

7

7
8

9

9
10
12

14
15
16
17

23

24

25

25
26
31

 
4

1.  Executive summary

REACH-EN-FORCE-3 is the third enforcement project of the Forum and encompasses the “Inspection 
and enforcement of compliance with registration obligations by manufacturers, importers and only 
representatives in close cooperation with customs”. The focus of the inspection has been on the registration 
duties of Article 5 and 6 of the REACH Regulation (EC) No 1096/2006 and, in particular, the principle “No 
data, no market”. The inspection phase in the 28 participating countries lasted between February 2013 
and August 2013 with 528 company inspections being carried out, covering an average of 6 substance 
inspections per manufacturer, importer and only representative (3 065 substances in total). 

In a novel and broad approach, all participating countries have utilised data on substances and mixtures from 
import declarations (typically an annual data set of predefined CN1 codes from various chapters of TARIC 
has been in use) to target their inspections of importers and only representatives. This data was gathered 
through cooperation with customs and in 85% of the participating countries the REACH enforcement 
authorities used the customs data provided them, while in 15% of countries, the risk assessment for 
targeting individual duty holders was performed by customs themselves. Companies with mainly an importer 
role (64%) and small and medium enterprises (67%) have been inspected.

As regards the economic group „manufacture of chemicals“, such companies represent about half of the 
inspected companies (53%) and are typically large companies. 30% of inspected companies fall into the 
economic group of retail and are typically small and medium sized enterprises. Based on the average 
numbers2 of manufactured or imported substances per inspected company in the tonnage band above 1 
tonne/year, REACH-EN-FORCE-3 inspections checked the compliance of relevant duty holders, with the 
number of substances manufactured or imported by a company ranging between 22 and 134 depending on 
the duty holder’s specific use profile. It was found that more than 50% of the companies inspected benefit 
from exemptions of their registration duty, mainly due to the phase-in status of substances and due to 
substances listed in Annex IV/V of REACH.

84% of the inspected companies have already filed a registration or a pre-registration while 55% of mostly 
large companies have already registered a substance (on average 19 registrations per company). 29% of 
companies have only pre-registered so far.

As a consequence of the enforcement project’s focus, the emphasis during inspections has been on importers 
(64%) and imported substances (71%). Manufacturers have been targeted in only 29% of the inspections. 
Inspections at only representatives have been clearly under-represented (7%) during phase 1 of the 
enforcement project which is also a major reason for the extension of inspection activities into 2014 during 
phase 2 of the REACH-EN-FORCE-3 project.

A 14% non-compliance rate was identified with respect to the registration duties of inspected companies. 
A missing registration is the most frequent reason for companies not being in compliance with registration 
duties. From the 528 companies inspected, 3% have been identified as “free-riders” who have not registered 
any of their substances requiring registration.

 CN: The CN comprises the first 8 digits of the 10-digit TARIC Goods Code, see code in the database TARIC: http://ec.europa.eu/

1 
taxation_customs/dds2/taric/

For classification of chemicals in the CN the European Customs Inventory of Chemical Substances ECICS is available: http://ec.europa.
eu/taxation_customs/dds2/ecics 

 The average number of manufactured or imported substances per inspected company is estimated based on the information given 

2 
by the inspected companies: the total number of manufactured or imported substances / substances in mixtures for all inspected 
companies divided by the number of inspected companies. 

Forum REACH-EN-FORCE 3 – Phase 1 Project Report5

It was also found that 5% of inspected substances are non-compliant and 3% of the substances lack the 
required registration. Moreover, within the top 12 substances of highest incident rate, 4 substances have 
hazardous properties. Missing registrations have also been found for 2 substances from the Substances of 
Very High Concern (SVHC) Candidate List.

As has been identified already in previous REACH-EN-FORCE projects, non-compliance rates for companies 
are higher for small and medium sized enterprises (17%) compared to larger companies (6%). When 
analysing companies holding different (single/multiple) REACH roles, only representatives show the highest 
non-compliance rate (25%) compared to importers (15%) and manufacturers (7%). The highest rate of non-
compliance (43%) is found in the group of only representatives performing this one role only.

A breakdown of non-compliance within an economic sector reveals that in general the “non-classical” 
chemical business shows higher incident rates (22%), while the “classical” manufacturers and distributors 
of chemicals are more compliant (11%). However, a more detailed analysis clearly indicates that core 
chemical manufacturing and distribution businesses (NACE divisions 20 and 46) have non-compliance rates 
higher than the mean value while, for example, manufacturers of mineral products and metals show better 
compliance than the average.

In general, the priorities of enforcement authorities have not been limited to using the enforcement method 
of sanctioning by imposing fines and initiating criminal complaint procedures on identified registration 
contraventions (11% each). Rather, the focus has been on first hand risk reduction measures. The reactions 
of enforcement authorities in cases of non-compliant companies have been focused on immediate actions 
by advising (71% of cases) or ordering remediation (32% of cases) and thus restoring to compliance 
the respective company and substance. Due to the complex regulatory nature of the cases, a focus of 
enforcement has also been to act beyond short term administrative measures and to commence in 37% of 
cases various kinds of follow-up activities. 

The overall conclusion of the REACH-EN-FORCE-3 project is that there is a considerable number of non-
compliant companies that do not fully observe REACH registration obligations. Moreover, it has been 
confirmed that importing companies need more attention as they are less compliant than manufacturers. 
The project has identified only representatives as a group specifically at risk of non-compliance with their 
registration duties. For this reason the Forum and Member States have decided to extend the enforcement 
project with further inspections in 2014. Special attention also needs to be drawn to economic sectors not 
belonging to “classical” manufacturers and distributors of chemicals. However, it must be noted that there is 
no indication of a systematic breach with the legislation and there is a low number of identified “free-riders” 
that do not register their substances at all.

REACH-EN-FORCE-3 has proven that REACH enforcement authorities in the 28 participating countries have 
established a functioning cooperation with customs. This allows enforcement authorities to make use of 
data from individual customs declarations in their routine inspections of REACH duties. The project design 
and the actual inspections in the participating countries have been successful in implementing harmonised, 
focused and balanced enforcement activities with regards to REACH registration duties. Consequently, this 
has contributed to a non-discriminatory enforcement approach in all Member States while achieving a broad 
coverage of relevant economic sectors in the market.

Enforcement of REACH registration obligations is – due to the complexity of the rules and the high number of 
various exemptions – an extremely demanding task for any National Enforcement Authority (NEA). Therefore, 
the complexity of the rules puts enforceability at stake as resources in NEAs are limited. Investigations 
targeted towards identifying relevant duty holders consume considerable resources even when starting from 
prepared data like that from customs declarations. Furthermore, investigations on the registration status of 
substances at an individual duty holder are highly complex in nature. It is the responsibility of the regulator 

Forum REACH-EN-FORCE 3 – Phase 1 Project Report6

to watch out for regulatory simplification in order to ensure better implementation of the registration duty 
and to reduce the unnecessary burden on duty holders and authorities who implement the REACH regulation.

In cases of non-compliant companies, enforcement authorities have focused their action on first-hand risk 
reduction measures by advising and ordering remediation. Subsequently, these measures have restored 
the legality of the substances concerned. However, to ensure non-discriminatory enforcement and a level 
playing field for the enterprises based in the internal market, it will become more and more important to 
reprove incorrigible duty holders who persistently breach their substance registration duties with intensified 
sanctioning (fining, criminal complaints, etc.).

Due to the enforcement project’s findings, the main recommendations are as follows:

•  The high non-compliance rate for only representatives’ needs to be addressed by the industries and 

industry stakeholders concerned. Only representatives have the highest non-compliance rate, which is 
twice the average rate for non-compliant companies. Only representatives are often non-compliant not 
only due to missing registrations, but also due to the breach of Article 8 of REACH regarding the duties of 
only representatives.

•  The high non-compliance rate for importers needs to be addressed by the industries and industry 

stakeholders concerned. Importers have a non-compliance rate at least twice that of manufacturers. 
Importers are often not aware and not familiar with their registration obligations under the REACH 
regulation.

•  The high non-compliance rate for actors which are not related to the chemical industry and chemical 
distribution sectors needs to be addressed by the industries and industry stakeholders concerned. 
These actors have a non-compliance rate twice that of the chemical industry and distribution sectors. 
These actors are often not aware and not familiar with their registration obligations under the REACH 
regulation.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report7

2.  Background

2.1 

BACKGROUND OF THE PROJECT

The Forum for Exchange of Information on Enforcement (Forum) has up to now conducted two coordinated 
enforcement projects in the European Economic Area (EEA). 

REACH-EN-FORCE 1 (REF-1) focused on obligations for manufacturers and importers of substances on their 
own or in mixtures with regards to pre-registration and information in the supply chain. 

REACH-EN-FORCE 2 (REF-2) focused on the compliance with the legal requirements imposed by REACH and 
CLP on those downstream users who are formulators of mixtures. 

The Forum adopted its third coordinated enforcement project, REACH-EN-FORCE 3 (REF-3) “Inspection 
and enforcement of compliance with registration obligations by manufacturers, importers and only 
representatives in close cooperation with customs”, at its tenth meeting in October 2011 (Forum-10). The 
REF-3 project is the logical continuation of the REF-1 and REF-2 projects and it aims to check compliance 
with REACH registration obligations of Manufacturers (M), Importers (I) and Only Representatives (ORs). 
Where necessary, compliance with the relevant registration duties may be enforced. The REF-3 project also 
endeavours to establish where possible, cooperation between Member States enforcement authorities and 
Customs Authorities (Customs).  

REF-3 focuses, as with REF-1, on the registration obligation of manufacturers and importers. The difference 
is that REF-1 mainly focused on the transitional regime based on Article 23 and 28 (pre-registration). After 
the registration deadline of 2010 and 2013 more substances needed to be registered and are subject for an 
inspection in REF-3. REF-3 also puts emphasis on ORs because a large number of registrations (8 693 unique 
company registrations which circa 30% are from ORs)3 are submitted by ORs. In addition to non-compliant 
companies that do not observe their registration obligations, one of the target groups for REF-3 inspections 
are the 8 693 registrants of full registrations listed in ECHA’s database. 

The project was guided by the Forum Working Group (WG) REF-3 project. This WG produced a project 
manual with guidance and recommendations for inspectors, a questionnaire with inspection items and a 
reporting tool. 

National coordinators were appointed in each participating country and supported by the WG. The national 
coordinators were primarily responsible for the training of the inspectors in their countries and managing for 
the WG the reporting of the inspection findings. For the latter purpose, the WG organised a web-conference 
with all appointed national coordinators to provide them with the information (manual and answers to 
questions) elaborated by the WG. 

For each company inspection, a questionnaire was completed by the inspector and submitted to the national 
coordinator via an electronic reporting tool. The report for a company inspection can document inspection 
results of up to 10 substances. This tool was introduced to enhance the preparation and submission of 
inspection reports, as well as to facilitate data processing and the analysis of project results. 

 Based on statistics from ECHA March 2014. Intermediate registrations have not been in focus of this enforcement project and are 

3 
excluded from this number.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report8

2.2 

LEGISLATIVE BACKGROUND

The REACH Regulation (EC) No. 1907/2006 lays down specific obligations for manufacturers, importers and 
downstream users of substances on their own, in mixtures and/or in articles. The regulation should ensure 
that substances placed on the market are used in such a way that human health and the environment are not 
adversely affected and that recommended measures to control the risks are taken. The regulation contains 
both general and detailed provisions on how manufacturers, importers and ORs should take appropriate 
measures in order to control and to identify what risks substances pose. If a company is acting as a supplier, 
they are obliged to provide information on the safe use of the substance to the recipient down the supply 
chain with a safety data sheet and/or to communicate any necessary risk management information. However, 
checking these communication obligations in the supply chain is not part of this project.

In order to ensure that any risk posed by substances is assessed appropriately and in order to make the 
relevant information generally available, manufacturers, importers and ORs are obliged to register their 
substances. This is the REACH principle of “No data, no market”.

The focus of the REF-3 enforcement project has been the investigation of compliance of manufacturers, 
importers and only representatives with their REACH duty to register their relevant substances. 

The majority of NEAs’ investigations in this project have started with data from customs declarations 
for imports provided by Customs. As a consequence, the project aims at giving special attention to the 
registration duty of importers and only representatives.

Any inspection result for importers that actually do not have a registration obligation due to a re-import 
situation (Art 2(7)(c) of REACH) or due to the presence of an OR (Art 8(3) of REACH) has not been reported. 
Inspection results for these duty holders will be reported only in phase 2 of the REF-3 project.

The REF-3 project is limited to the obligations stipulated in the REACH Regulation. Obligations imposed by 
the CLP Regulation are not in the scope of this project.

Table 1: Obligations checked and eventually enforced within the project 

Article in 
REACH

Description

5

6

8

No data, no market

General obligation to register substances on their 
own or in mixtures

Only representative of a non-Community 
manufacturer

12.2

Information to be submitted depending on tonnage

28

Duty to pre-register for phase-in substances

Remark

-

Investigations and inspections have also covered 
various exemptions to the registration obligation, 
e.g. the exemptions defined in Art 2

Inspections have taken place at the importers 
covered by an OR and at the ORs, however only 
the results of ORs have been reported

Art 12(1) is enforced by “Evaluation”, only. Art 
12(2) is relevant for NEAs in terms of cross 
checking the annual tonnages on site and in the 
dossier

Late pre-registrations have also been covered by 
the inspections

Forum REACH-EN-FORCE 3 – Phase 1 Project Report9

3.  Results of the project

3.1 

PARTICIPATION AND NUMBER OF COMPANY INSPECTIONS

The REF-3 project was performed by 28 Member States and inspections of 528 companies were included in 
the project. Table 2 lists the participating countries and the number of national inspections reported. 

During inspections it was observed that some companies only have a role as a downstream user (DU)/
distributor and not, as expected when selecting the companies to be inspected, having manufacturer, 
importer or OR roles. The NEAs have identified a number of such cases, and these inspections are not 
included in the scope of this project. Instead, they will be part of the scope of phase 2 of the REF-3 
project. For example, in some countries the number of such inspections is up to 80% of the total number of 
inspections. A frequent reason is the presence of an OR who has taken over the registration obligation. 

The varying economic conditions between countries, disparity in the availability of resources and/or the size 
of the country could provide an explanation as to why certain countries have performed more enforcement 
actions within the scope of this project than others.

Moreover, additional inspections have been carried out on the REACH Regulation within the scope of other 
national projects. Therefore, this report does not reflect all the inspections carried out in the Member States 
for checking compliance with REACH.

Table 2: Participating countries and company inspections included in the project4  

Country

Number of company inspections included in the project

Austria

Belgium

Bulgaria

Cyprus

Czech Republic 

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Iceland

Ireland

Italy

Latvia

17

18

42

10

17

14

14

1

19

73

27

60

3

20

37

7

 In some countries the number of inspections not included in the report could be over 100% of the total number of inspections 

4 
reported for this project.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report10

Liechtenstein 

Luxembourg

Lithuania 

Malta

Netherlands

Poland

Portugal

Slovakia

Slovenia

Spain

Sweden

United Kingdom

Total number

2

05

13

5

18

20

15

7

8

27

19

15

528

3.2 

ROLE OF INSPECTED COMPANIES UNDER REACH AND THEIR SIZE

Enterprises may have various roles under REACH. Some assume a variety of roles at the same time. The 
distribution of REACH roles observed by inspectors for the checked companies (multiple responses possible) 
is given in Figure 1. 73% (383 from 528) of the inspected companies having REACH duties only have one 
single role (M, I or OR). 5

Figure 1: Distribution of company roles (n= 528).

5 

Inspections not finished by the date of the report

Forum REACH-EN-FORCE 3 – Phase 1 Project Report11

According to the scope of the project, all the inspected companies act as either a manufacturer (M), 
importer (I) or only representative (OR)6. Importers are represented at a higher rate than manufacturers. 
The proportion of companies acting as ORs are relatively small (11%) and very few of them act solely 
as ORs (4%). Any companies with an additional role as a DU/distributor have not been considered in the 
project report.

Companies of all size categories according to the EU standard scale7 were included in the inspections. Micro, 
small and medium-sized companies (SMEs) are represented in relatively equal proportions and make up 67% 
of the entire sample. One third of the inspected companies (32%) were larger enterprises, not belonging to 
the SME category.

The distribution of company size is illustrated in Figure 2 (see also Figure A1 in Annex 2) and is compared 
with the roles in Figure 3. The proportion of SME (353) to non-SME companies (167) is 2:1. 

Figure 2: Distribution of company sizes (n=528)

6  Companies may assume several roles, e.g. a manufacturer can be a manufacturer and having other roles (inter alia) and companies 
may assume only one role (role only), The group “role only” is part of the group “inter alia”.

7  Commission Recommendation 2003/361/EC

Forum REACH-EN-FORCE 3 – Phase 1 Project Report12

Figure 3: Distribution of company sizes and REACH roles of companies (role inter alia)8 

There is a good balance between the sizes and the roles of the inspected companies and therefore a good 
basis for further analysis of the received data.

3.3 

TYPES OF THE INSPECTED COMPANIES ACCORDING TO THEIR ECONOMIC ACTIVITIES

The range of surveyed economic activities represented by the inspected enterprises was specified in the 
inspection report by the NACE9 code (4 digit NACE classes). In order to present all economic activities that 
are relevant for the 528 companies inspected, the assigned NACE classes have been grouped into 4 relevant 
NACE units according to Table 3. The most frequent NACE divisions covered by the inspections are shown in 
Annex 2, in Figures A2 and A3; in Table A2 an example of NACE divisions and classes relevant in this project 
are shown.

Table 3: Used NACE divisions combinations in forming the four NACE units

NACE Unit

NACE definitions covered

A (Manufacture of chemicals)

Manufacture of chemicals and chemical and refined petroleum products

B (Wholesale, retail)

Wholesale, retail, transport and storage,  

C (Manufacture of non-chemicals)

Manufacture (other than chemicals) and mining,  
NACE Sections B and C 

D (Other)

Construction, energy/water supply, technical activities 

8 

 For absolute numbers, see Table A1 in Annex 2.

  NACE, the Statistical Classification of Economic Activities in the European Community, is a European industry standard 

9 
classification system for economic activities, Regulation (EC) No 1893/2006.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report13

More than half of inspected companies (53%) fall into the group “manufacturer of chemicals”. The activities 
reported for this group include the preparation of paints and varnishes as well as detergents, cleaning and 
polishing mixtures and manufacture of basic chemicals, fertilisers and nitrogen compounds, plastics and 
synthetic rubber in primary forms. Other sectors with a major share of the number of inspections in the 
project are wholesale / retail (30%) and manufacture of non-chemicals (11%). While non-SMEs are often 
manufacturers, the small and micro enterprises which were inspected are often active in wholesale/retail.

Table 4: Main economic activities in the scope of the project grouped into NACE units. 

NACE Units

Number of companies

Fraction of total number of 
inspected companies (%)

A Manufacture of chemicals

B Wholesale, retail

C Manufacture of non-chemicals

D Other

281

160

58

29

53

30

11

6

Figure 4: Distribution of company size for each economic activity - NACE unit10

10   For absolute numbers see Table A3 in Annex 2.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report14

INSPECTED COMPANIES’ TOTAL NUMBER OF MANUFACTURED AND IMPORTED11 SUBSTANCES 

3.4 
AND MIXTURES 

In the inspected companies substances and mixtures are manufactured as well as imported with 38% (200) 
of the inspected companies doing both. In Table 5, the findings on this issue are reported. 

Table 5: Average number of substances and substances in mixtures that an inspected company is manufac-
turing or importing in amounts of > 1 tonne/year

Average number manufactured

Average number imported

Mixtures

Substances

134

25

25

22

45% (232) of the inspected companies are manufacturing substances in amounts > 1 tonne/year. The vast 
majority manufacture substances on their own (91%), while 30% also manufacture substances in mixtures 
(a company could manufacture both: substances and substances in mixtures). 47% of the manufacturers 
benefit from at least one substance exempted from the REACH registration duty. On average, 15% of the 
manufactured substances benefit from registration exemptions. 

A considerable amount of inspected companies (76%, 390) are importing substances in amounts > 1 tonne/
year, of which the majority import substances on their own (82%), whilst 35% import substances in mixtures 
(a company could import both: substances and substances in mixtures). 54% of the importers benefit from 
at least one substance exempted from the REACH registration duty. On average, 35% of the imported 
substances benefit from registration exemptions. 

As can be seen from Table 6, there are two major reasons for substances being exempted from the REACH 
registration duty. Most exemptions are valid either because of an existing pre-registration for a phase-in 
substance (Art 28 of the REACH Regulation) or due to the substances being listed in Annex IV or V of the 
REACH Regulation (Art 2(7)(a) and 2(7)(b) of the REACH Regulation).

As DUs are not considered in REF-3 phase 1, the exemptions for ORs and on Re-import are therefore of 
reduced incidence.

Table 6: Distribution of different possible exemptions from substance registration relevant for the inspected 
companies

Manufacture (N=104)

Import  (N=201)

A. Exemptions for phase-in substances  

32

31%

75

B. Exemptions for substances from the scope of REACH

B.1 Substances manufactured or imported less than 1 
tonne per year

B.2 Waste

B.3 Polymers

B.4 Others

-

5

2

13

6

-

5%

2%

12%

6%

-

5

7

6

37%

-

2%

3%

3%

11   For the purpose of this statistics on substances imported by the inspected companies, the substances covered by activities of an 
OR have been also regarded as “imported substances”.

Forum REACH-EN-FORCE 3 – Phase 1 Project ReportC. Exemptions from registration due to special use

C.1 Reimport

C.2 Recycling

C.3 Others

-

1

9

D. Exemptions from registration due to inclusion in Annex IV 
and V

28

E. Others

E.1 OR

E.2 NONs

E.3 Others

Total

15

-

1%

8%

27%

-

2%

6%

-

4

28

44

-

16

7

9

-

2%

14%

22%

-

9%

3%

5%

-

2

6

104

100%

201

100%

3.5 

REGISTRATION OBLIGATIONS

According to Article 5 of the REACH Regulation, substances on their own, in mixtures or in articles shall not 
be manufactured in the Community or placed on the market at one tonne or more per year unless they have 
been registered. If companies not only formulate mixtures, but also manufacture or import substances as 
such or in mixtures in quantities of one tonne or more annually, and if no exemptions are applicable, it is 
mandatory to submit registrations to ECHA.

Inspections at companies on registration obligations have been undertaken in the first half of 2013 until 
August 2013. Therefore, not all inspections undertaken during this project could cover a compliance 
assessment related to the second registration deadline for phase-in substances, which was scheduled for 31 
May 2013. 

According to information given by the 528 inspected companies, 84% (442 companies) have already filed 
at least one registration or pre-registration. 55% (289) of the inspected companies have at least one 
substance already registered and 29% (153) of the inspected companies have so far, only pre-registered. 
The inspections at 289 registrants cover 3% of all registrants recorded in ECHA’s registration database3. 

16% (86) of companies hold neither registrations nor pre-registrations for their substances in their role as a 
manufacturer, importer or OR. Some might not be in compliance with their REACH registration duty (see the 
average non-compliance rate given in Section 3.7) while others might benefit from additional registration 
exemptions listed in Table 6 for all of their substances.

The 442 registrants and pre-registrants have filed a total of 54 658 pre-registrations and 5 370 
registrations, making an average of 19 registrations per registrant for the 298 companies that registered 
substance(s)12.

Table 7 lists the average number of registrations and pre-registrations per company sorted by size, role or 
economic sector.

12   The minimum number of registrations per company is 1, the maximum number of registrations per company is 1 239.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report16

Table 7: Average number of registrations and pre-registrations per company 

Type of duty holder

Average number of 
registrations per company

Average number of pre-
registrations per company

Company size

Micro

Small

Medium

non-SME

Company role (inter alia)

M

I

OR

NACE unit A-D

A

B

C

D

18

3

7

31

22

21

40

21

11

3

36

173

61

91

166

111

116

402

114

100

10

630

The table indicates that on average, non-SME companies are more active in filing registrations than SMEs. 
Also, companies with the role of an OR are the most active registrants (and pre-registrants). For the result of 
NACE unit D (“other”) it has to be highlighted that the number of company inspections is low (see Table 4) and 
only relatively few registrations were observed.

3.6 

RESULTS OF THE COMPANY INSPECTIONS

In the first phase of inspections for project REF-3, a total of 3065 substances were reported as being 
checked for compliance in relation to their registration obligations. The general assessment of non-
compliance rates for inspected substances in Section 3.7 will be based on these 3065 substances. 

The breakdown of uses gives evidence that a majority of the 3065 substances actually examined in this 
enforcement project are imported substances (71%) and the majority of companies (64%) have the role of an 
importer for their inspected substances. Manufacturers have been targeted in only 29% of the inspections. 
Inspections at ORs have been clearly under-represented (7%) during the first phase of the enforcement 
project, which is also a major reason for extending inspection activities into 2014 (phase 2 of the REACH-EN-
FORCE-3 project). 

For a subset of 755 inspected substances more details on investigation findings have been documented. On 
average, investigation results for 2 such substances have been documented per company. 3% (23) of the 
755 documented substances have covered 16 different substances from the 151 entries of the actual SVHC 
Candidate List published on the web page of ECHA13. 

32% (242) of the 755 documented substance inspections in the enforcement project have covered 145 
different substances from the 4485 Annex VI entries for harmonised classification and labelling of the CLP 
Regulation in the version of the third amendment to the technical progress. 

13   List status on 8 March 2014.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report17

The figures also reveal that the possibility to identify ORs based on customs data for import 
consignments of chemicals is limited, as ORs are not consignees or suppliers. Compared to the 
breakdown of roles for all 8 693 registrants of full registrations recorded at ECHA3 (46% manufacturer 
role, 34% importer role, 30% OR role), the ORs are clearly under-represented in the inspection results 
of this enforcement project.

However, the shortcomings during the first phase  of the project will be better dealt with during phase 2 of 
the project in 2014. It is expected that by the end of the enforcement project more of the 2983 ORs recorded 
in ECHA’s data base will be addressed by the inspections. 

Taking into account the 32 621 full substance registrations filed at ECHA3, the number of inspected 
substances (3 065) are in an order of magnitude of 10% of all existing relevant substance registrations. 

In looking at all registration dossiers filed at ECHA3, 85% of the registration dossiers were submitted from 
large companies. Therefore, the sample of inspected companies in the enforcement project does not reflect 
the proportion of SMEs who have filed a registration dossier with ECHA. The reason for this is that the 
enforcement project has aimed at a more balanced sample of companies of all sizes for the inspection.

3.7 

NON-COMPLIANCE ISSUES AND MEASURES TAKEN

Considering all the duties following from a company’s registration obligations, 75 of the 528 inspected companies 
are non-compliant for at least one substance. From these, 56 companies failed to register at least one substance.

The inspected companies did not comply with the registration duties for 143 substances including 92 
substances with a missing registration.  

Table 8: Non-compliance rates of inspected companies and inspected substances

Non-compliance rate

Inspected companies

Inspected companies with missing substance registrations

Inspected companies with all substance registrations missing (“free riders”)

Inspected substances

Inspected substances with a missing registration

(%)

14%

11%

3%

5%

3%

When a company was not in compliance, on average 2 non-compliant substances were reported. 

Within the group of companies missing their obligatory registration for more than one substance, 14 
inspected companies (3%) were reported to have all the required substance registrations missing (“free-
riders”). The worst case investigated showed 10 non-compliant substances out of 10 substances checked. 

The highest number of non-compliant substances identified in a single company has been 13 (out of 188 
checked substances).

An analysis of the number of non-compliant companies and the participating countries where these non-compliant 
companies where located, shows that non-compliant companies are found in a range of different countries:

Forum REACH-EN-FORCE 3 – Phase 1 Project Report18

•  non-compliant companies have been observed in 19 participating countries;
• 

the number of non-compliant companies in each participating country varies from 0 to 13.

Due to the high number of different substances investigated during the inspections (486 different substance 
identities) the incidence of non-compliance for each of the inspected substances does not exceed 4. The 
incidence of non-compliance for a substance does not fully correlate with the frequency of inspections 
focused on the substance. 

In two inspections on SVHC the required registration was missing (9% of all 23 inspections on SVHC). 28 
inspections on substances with harmonised classification have identified non-compliance due to registration 
duties (12% of all 242 inspections on substances with harmonised classification). 

Inspections for both SVHCs and substances with harmonised classification indicate a higher non-compliance rate 
for these two sub-groups of substances compared to the average non-compliance of all substances inspected.

Moreover, within the top 12 substances of highest incident rate, 4 substances have hazardous properties.

The distribution of non-compliant companies and substances for which the registration obligations are not 
fulfilled are analysed in the following Sections in terms of company size, the role of the companies and the 
economic sectors affected. Moreover, the reasons for the non-compliance and the measures taken have 
been investigated.

3.7.1  Company size

The inspected companies and non-compliant companies could be classified based on the size of the company 
in micro, small, medium-sized enterprises (SME) and non-SME companies. 

SMEs show a higher non-compliance rate compared to non-SMEs which is evident when looking at the set of 
all non-compliant companies (the vast majority of which are SME) as well as when analysing the number of 
non-compliant companies among inspected companies of a certain size, i.e. there is a much higher number -in 
absolute terms- of non-compliant companies when looking at SMEs compared to non-SMEs (see Table 9).

Compared to non-SMEs, there is again a much higher number (in absolute terms) of SMEs where non-compliant 
substances were detected during inspections. However, when looking only at non-compliant companies, 
relatively more non-compliant substances were detected for non-SMEs than for SMEs (see Table 10).

Table 9: Company size and non-compliant companies (n=71)14

Company size

Distribution of inspected 
companies 

Micro

Small

Medium

Non-SME

Total

(N=528)

21%

22%

25%

32%

100%

14  Not considering the “not reported” data.

Distribution for 
non-compliant 
companies

Proportion of non-compliant 
companies within each company 
size group14

(N=71)

28%

30%

28%

14%

100%

18% (20/110)

18% (21/115)

16% (20/128)

6% (10/167)

(71/515)

Forum REACH-EN-FORCE 3 – Phase 1 Project Report19

Table 10: Company size and percentage of non-compliant substances of the controlled substances 

Company size

Micro

Small

Medium

non-SME

9% non-compliance

8% non-compliance

5% non-compliance

2% non-compliance

2 non-compliant substances per
non-compliant company
(353 SME companies)

3 non-compliant substances per non-
compliant company
(167 non-SME companies)

3.7.2  Role of the non-compliant companies

How frequently a non-compliant company is found also depends on the role of a company. In addition, 
differences appear between companies having only one role and companies having multiple roles (e.g. 
between a “manufacturer only” and a “manufacturer inter alia”). 

The rate of non-compliance is higher in cases where the role of importer and OR is the single role, compared 
to companies having multiple roles. Companies with single roles tend to be less compliant than the 
companies having several roles.

The rate of non-compliance for importers is higher compared to that of manufacturers. The highest non-
compliance rate is found for the role of the OR, especially if the OR is the only role.

The same trend can be observed for the related non-compliant substances. If the OR is the single role, the 
non-compliance rate for substances is 22 % (see Table 11).

Table 11: Non-compliance distribution for the different roles of duty holders 

Role

Manufacturer only 

Manufacturer inter alia

Importer only 

Importer inter alia

OR only

OR Inter alia

Non-compliant 
companies

Non-compliant substances of companies 
with the role

(N=143)

(N=75)

8 %

7 %

18 %

15 %

43 %

25 %

2 %

1 %

7 %

5 %

22 %

8 %

3.7.3  Economic sectors of non-compliant companies

The companies belonging to the NACE units of manufacturers of chemicals and wholesale/trade (NACE unit 
A and B) show the highest incidence of non-compliance in terms of total number of non-compliant companies. 
The sectors to be regarded as non-typical for chemical activities (NACE unit C and D) show the highest non-
compliance rate within the NACE unit (see Table 12).

Forum REACH-EN-FORCE 3 – Phase 1 Project Report20

Table 12: Non-compliant companies of inspected companies within NACE unit

A

B

C

D

Total

Non-compliance rate within the NACE unit

11%

14%

22%

28%

Number of non-compliant companies/  
number inspected companies

32/281

22/160

13/58

8/29

75/528

Some of the economic sectors are typical of the chemical industry like the “Manufacture of chemicals and 
chemical products” (NACE 20). This sector shows a non-compliance rate of 15% and is similar to wholesale 
(NACE 46). For further details see Table 13. For other economic sectors, see Table A4 in Annex 2. 

Table 13: Non-compliance distribution of inspected companies within selected economic activities / NACE 
Division (n=75)

NACE Division

Number of non-compliant companies/  
number inspected companies

Rate of non-
compliant 
companies

20

23

24

46

Manufacture of chemicals and 
chemical products

Manufacture of other non-metallic 
mineral products

Manufacture of basic metals

Wholesale trade, except of motor 
vehicles and motorcycles

27/181

2/32

1/26

19/145

3.7.4  Reasons for non-compliance and observations

15%

6%

4%

13%

Non-compliance of registration duties has different causes. In most cases of non-compliance, companies 
have not submitted the required registrations for their substances. About one quarter of the non-compliant 
substances originating from an OR did not fulfil the required specific registration duties of an OR according 
to Article 8 of REACH (see Table 14).

Table 14: Distribution of the reasons of non-compliance for inspected companies and checked substances 
(multiple responses are possible)

Reason for non-compliance

Companies 

Substances (N=143)*

Substance identity

Missing registration

Wrong tonnage band

Not all REACH obligations according to the applicable role 
M/I/OR

Criteria and/or obligation of an OR not fulfilled, missing 
evidence for appointment of an OR

* see section 3.7

(N=75)*

5 (7%)

56 (76%)

2 (4 %)

7 (9 %)

15 (20%)

17 (12%)

92 (64%)

6 (4%)

16 (11%)

37 (26%)

Forum REACH-EN-FORCE 3 – Phase 1 Project Report21

A more detailed investigation of a company’s obligation to file a registration dossier for substances has been 
carried out for a reduced sample of 51115 substances. This detailed investigation has also focused on the 
possibility of making use of phase-in options for the registration at the time of the inspections (including 
also some inspections that have been undertaken prior to the registration deadline 31 May 2013) or other 
existing exemptions from registration obligations. In total, 58% (298) of the 511 substances investigated 
for such detail have not been registered. 

The prevailing reason for substances not being registered at the time of inspection is due to companies using 
one of the various registration exemptions (49%, 253/511):

•  21% (107) of the substances inspected were not registered at the time of the inspection because the 

company intends to register by 31.05.2018

•  2% (11) of the substances inspected had not been registered at the time of the inspection (before 

31.5.2013) because the company intended to register by 31.05.2013

•  26% (135) of the substances were not registered because the company were making use of existing 

registration exemptions.

Only 9 % (45) of the substances thus investigated were missing the required registration and are cases of 
non-compliance. 

An investigation that gives more detail on companies using the various existing exemptions from the 
registration obligation can be found in the report of the Forum enforcement project REF-116. 

39 ORs have been specifically addressed by inspectors for their compliance with the OR duties defined in 
Article 8 of REACH. 35% (15) of them have been proven to be non-compliant for a total of 37 substances. The 
39 inspected ORs have been reported to cover between 1 and 60 importing downstream users and annual 
tonnage bands from 1 up to >1000 ton/year. Of the 37 registrations lacking compliance with OR duties, 
almost 50% (18) cover substances with hazardous properties. 

3.7.5  Non-compliance and measures taken

During the first operational phase of REF-3, 75 companies have been identified as being non-compliant 
regarding their registration obligations.

In reaction to contraventions, inspectors imposed various measures in order to correct non-compliance by 
providing verbal or written advice and issuing administrative orders, but also by imposing sanctions such as 
fines and criminal complaints.

Due to the first operational phase being short, not all inspectors could conclude the investigations completely. 
Therefore, follow up activities were still on-going or no measures had been taken and these would follow henceforth. 

A high percentage of corrective measures taken to correct incompliant companies took the form of written 
and verbal advice. Imposing measures are not always advisable as companies are obliged by law to comply in 
any case on their own initiative without an authority’s order. Altogether, the percentage of applied sanctions 
against an offender in the form of a fine or criminal complaint is low. It is important to note, that national 
situations and legal action against offenders specific to each particular situation of non-compliance might 
vary among the participating countries.

15   When asked to clarify the actual registration obligation in more detail for one selected substance per inspected company, 
inspectors have reported back details for 511 substances.

16   See report: http://echa.europa.eu/documents/10162/13577/forum_ref-1_consolidated_report.pdf 

Forum REACH-EN-FORCE 3 – Phase 1 Project Report22

Different approaches may exist in any one Member State. It seems that in terms of sanctioning missing 
substance registrations, rather soft measures are taken by NEAs in cases where companies do not comply 
with registration obligations.

During the first operational phase, results of 6 inspections obtained in a Member State have been forwarded 
to the other Member States where these companies are located. 4 cases related to potentially non-
compliant companies and 2 other cases, have been forwarded. For this purpose different communication 
channels have been used (Table 15).

Table 15: Communication channels used to forward information on inspections to other MS (for one case 
multiple choice is possible)

Used communication channels

To National Enforcement Authority 

To National Competent Authority 

To Forum Member 

To National REF-3 Coordinator 

To NEA Contact Point / Focal Point in RIPE 

Feedback from the other Member State approached is already available 

Number

1

2

2

1

2

0

The limited use of opportunities for liaising with authorities in other Member States might have been due to 
difficulties in using the REACH information portal for inspectors (RIPE). Communication via RIPE has been 
implemented only during the operational phase of the enforcement project. 

Forum REACH-EN-FORCE 3 – Phase 1 Project Report23

4.  Overall conclusions

The REACH-EN-FORCE-3 project has shown that in the year 2013 there were a considerable number of non-
compliant companies not observing REACH registration obligations. In 75 of the 528 inspected companies 
non-compliance was detected. This needs to be considered as a very high non-compliance rate taking into 
account the many years since the entry into force of REACH. It has also been seen that more attention needs 
to be given to importing companies as they are less compliant than manufacturers. Furthermore, the project 
has identified only representatives as a specific group at risk of non-compliance with their registration 
duties. For this reason also, an extension of the project with further inspections in 2014 has been agreed on 
by the Forum and Member States, at the Forum-16 meeting. 

In future, special attention also needs to be drawn to economic sectors not belonging to the “classical” 
manufacturers and distributors of chemicals. Again it has been confirmed that SMEs have more problems in 
ensuring their compliance compared to larger enterprises. However, there is no indication of a systematic breach 
with the legislation and the numbers of identified “free-riders” that do not register their substances at all, are low.

Due to the high number of detailed investigations performed during the inspections of 528 duty holders 
as well as the substantial amount of data obtained, a realistic picture of the level of compliance of 
manufacturers, importers and only representatives can be formed.

REACH-EN-FORCE-3 has proven that REACH enforcement authorities in the 28 participating countries have 
established a functioning cooperation with customs which allows for making use of data from individual customs 
declarations in routine inspections of REACH duties. The project design and the actual inspections in the 
participating countries have been successful in implementing well-distributed, harmonised and focused inspections 
and enforcement activities. Subsequently, this has contributed to a non-discriminatory enforcement approach in all 
Member States while achieving a broad coverage of relevant economic sectors in the internal market.

Although import declarations do not necessarily and not always directly indicate the actual REACH duty 
holder, the customs declarations are both an efficient and effective tool to start with in case of REACH 
control activities focused on importers and ORs.

Enforcement of REACH registration obligations is – due to the complexity of the rules and the high number 
of various exemptions – an extremely demanding task for any NEA. Eventually the complexity of the rules 
puts enforceability at stake as resources in NEAs are limited. Investigations targeted at identifying relevant 
duty holders consume considerable resources in NEAs even when starting from prepared data like customs 
declarations. In addition, investigations of individual duty holders concerning the registration status of their 
substances are highly complex in nature. In such situations, efficient tools like data access in RIPE are of 
utmost importance. However, the regulator has to be on the look-out for regulatory simplification in order 
to ensure better implementation of a registrant’s registration duty and to reduce the unnecessary burden on 
duty holders and the authorities who have roles within REACH.

In cases when companies are found to be non-compliant, enforcement authorities have focused their 
action on first hand risk reduction measures by advising and ordering remediation. Subsequently, these 
measures have restored to legality the substances concerned. A focus of enforcement has also been to act 
beyond short-term administrative measures and to start follow-up activities of various kinds. It can be seen 
therefore that the priorities for enforcement authorities have not been limited to sanctioning and initiating 
criminal complaint procedures. Despite this more ‘soft’ approach, in order to ensure non-discriminatory 
enforcement and a level playing field for the enterprises in the internal market it will become more and more 
important to reprove incorrigible duty holders who persistently breach their substance registration duties 
with intensified sanctioning (fining, criminal complaints, etc.). 

Forum REACH-EN-FORCE 3 – Phase 1 Project Report24

5.  Recommendations

•  The high non-compliance rate for only representatives’ needs to be addressed by the industries and 
industry stakeholders concerned. Only representatives have the highest non-compliance rate; twice 
the average rate for non-compliant companies. Often, only representatives are non-compliant not only 
because of missing registrations, but also due to the breach of Article 8 of REACH relating to the duties 
of only representatives.

•  The high non-compliance rate for importers needs to be addressed by the industries and industry 

stakeholders concerned. Importers have a non-compliance rate at least twice the non-compliance rate of 
manufacturers. Importers are often not aware and not familiar with their registration obligations under 
REACH.

•  The high non-compliance rate for SMEs needs to be addressed by the industries and industry stakeholders 

concerned. SMEs have a non-compliance rate which is twice the non-compliance rate of non-SMEs.

•  The high non-compliance rate for actors which are not related to the chemical industry and distribution 

sectors needs to be addressed by the industries and industry stakeholders concerned. These actors have 
a non-compliance rate that is twice the non-compliance rate of the chemical industry and distribution 
sectors. These actors are often not aware and not familiar with their obligations for REACH registration.

•  Enhanced non-compliance rates for the classical chemical industry sector (NACE Division 20) needs to be 
addressed by the industries and industry stakeholders concerned. In contrast to what would be expected, 
the classical chemical industry sector is not the economic sector that is most aware of their REACH 
registration duties. However, this sector does not have the lowest non-compliance rate compared to the 
other economic sectors concerned.

Forum REACH-EN-FORCE 3 – Phase 1 Project Report25

6.  Annexes

6.1 

 ANNEX 1: LIST OF THE RELEVANT COMMUNITY LEGAL ACTS

•  Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 

2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), 
establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council 
Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 
76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC. 

•  Regulation (EC) No 1893/2006 of the European Parliament and of the Council of 20 December 2006 

establishing the statistical classification of economic activities NACE Revision 2 and amending Council 
Regulation (EEC) No 3037/90 as well as certain EC Regulations on specific statistical domains.

•  Council Regulation (EEC) No 2913/92 of 12 October 1992 establishing the Community Customs Code

•  Council Regulation (EEC) No 2658/87 of 23 July 1987 on the tariff and statistical nomenclature and on 

the Common Customs Tariff (TARIC)

•  Commission Recommendation2003/361/EC of 6 May 2003 concerning the definition of micro, small and 

medium-sized enterprises

Forum REACH-EN-FORCE 3 – Phase 1 Project Report26

6.2 

ANNEX 2: SUPPLEMENTARY FIGURES AND TABLES 

Figure A1: Distribution of the company sizes

Table A1: Distribution of company sizes and role (n=528).

Role inter alia

Micro

Small

Medium

Non-SME

Not reported

M

I

OR

28

73

12

34

90

10

64

94

16

116

128

17

4

4

1

Forum REACH-EN-FORCE 3 – Phase 1 Project ReportFigure A2: Range of a selection of surveyed economic sectors represented by the inspected enterprises 
specified by the NACE code

27

Forum REACH-EN-FORCE 3 – Phase 1 Project Report28

Figure A3: Range of surveyed economic sectors represented by the inspected enterprises specified by the 
NACE Division

Forum REACH-EN-FORCE 3 – Phase 1 Project ReportTable A2: Economic sectors most often covered by company inspections

NACE unit Most important NACE Sections covered during inspections in REF-3

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

A

B

B

B

B

C 20 

Manufacture of chemicals and chemical products

C 20.11  Manufacture of industrial gases

C 20.13  Manufacture of other inorganic basic 

chemicals

C 20.14  Manufacture of other organic basic chemicals

C 20.15  Manufacture of fertilisers and nitrogen 

compounds

C 20.16  Manufacture of plastics in primary forms

C 20.30  Manufacture of paints, varnishes and similar 

coatings, printing ink and mastics

C 20.59  Manufacture of other chemical products n.e.c.

C 21 

Manufacture of basic pharmaceutical products and 
pharmaceutical preparations

C 21.10  Manufacture of basic pharmaceutical products

C 21.20  Manufacture of pharmaceutical preparations

C 23 

Manufacture of other non-metallic mineral products

C 23.52  Manufacture of lime and plaster

C 24 

Manufacture of basic metals

C 24.10  Manufacture of basic iron and steel and of 

ferro-alloys

C 24.42  Aluminium production

C 24.43  Lead, zinc and tin production

G 46  Wholesale trade (except of motor vehicles and 

motorcycles)

G 46.12  Agents involved in the sale of fuels, ores, 
metals and industrial chemicals

G 46.75  Wholesale of chemical products

G 46.90  Non-specialised wholesale trade

29

Number of 
company 
inspections

181

8

33

48

12

12

8

25

29

15

11

32

16

26

7

6

6

145

14

84

7

Table A3: Distribution of company sizes and economic sectors (n=528)

Company size

NACE-groups

Micro

Small

Medium

Not SME

Not reported

A

B

C

D

33

57

8

12

51

44

11

9

73

35

16

4

121

22

21

3

3

2

2

1

Forum REACH-EN-FORCE 3 – Phase 1 Project Report 
 
 
 
 
 
 
30

Table A4: All NACE Divisions covered by REF-3 inspections and assignment of NACE units, inspections and 
non-compliances per NACE Division

NACE Divisions

NACE unit A – D

Number of company 
inspections

Number of non-compliant 
companies

07

08

09

10

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

32

33

35

38

39

43

45

46

47

51

52

62

70

71

72

74

82

94

C

C

C

C

C

C

C

C

C

C

A

A

A

A

A

A

C

C

C

C

C

C

C

C

D

D

D

D

B

B

B

B

B

D

D

D

D

D

D

D

3

4

1

8

2

2

1

2

2

1

7

181

29

6

32

26

8

3

3

6

1

1

9

1

3

2

1

4

2

145

8

3

2

1

1

2

3

4

1

1

-

-

1

1

1

1

-

-

1

-

-

27

-

2

2

1

3

1

-

1

-

-

3

-

1

-

-

1

1

19

1

1

-

1

-

-

-

4

-

1

Forum REACH-EN-FORCE 3 – Phase 1 Project Report31

6.3 

ANNEX 3: GLOSSARY 

CMR  

a substance or mixture which is carcinogenic, mutagenic or toxic to reproduction

CN  

DU  

I 

M   

Combined nomenclature

Downstream user

Importer

Manufacturer

NACE: 

Nomenclature of Economic Activities - Nomenclature des Activités Économiques dans la    
Communauté Européenne

NEAs 

National Enforcement Authorities

OR  

Only representative

REACH   

Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and  
Restriction of Chemicals 

REF  

SME 

REACH-EN-FORCE, Coordinated Enforcement Project of the Forum 

 Small and Medium Sized Enterprises

SVHC 

 Substance of very high concern

WG 

 Working Group of the Forum

Forum REACH-EN-FORCE 3 – Phase 1 Project Report 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
european chemicals agency
annankatu  18, p.o. box  400, 
fi -00121 helsinki, finland
echa.europa.eu

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