REACH Regulation and Cosmetics: What Brand Owners Must Know

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the EU's overarching chemical safety regulation, and it applies to cosmetic brands mainly through their raw materials, not their finished products. Finished cosmetics are primarily governed by the separate Cosmetics Regulation (EC) No 1223/2009, but REACH still reaches into your supply chain through substance registration, Safety Data Sheets, restricted substances, and the SVHC Candidate List. This guide explains exactly where REACH intersects with a cosmetic brand's responsibilities, and where it doesn't.

What REACH Actually Regulates

REACH is set out in Regulation (EC) No 1907/2006 and administered by the European Chemicals Agency (ECHA). Its core purpose is to ensure that chemical substances manufactured or imported into the EU in quantities of one tonne or more per year are registered, their hazards evaluated, and where necessary, subject to authorisation (for substances of very high concern) or restriction (limits or bans on use). The UK operates a parallel framework, UK REACH, following Brexit, administered by the HSE.

REACH applies broadly across all industries that manufacture, import, or use chemical substances it isn't a cosmetics-specific law. This is precisely why its relationship with cosmetic brands is so often misunderstood.

Why Finished Cosmetics Aren't Directly Registered Under REACH

A finished cosmetic product itself is not registered under REACH. Instead, the Cosmetics Regulation (EC) No 1223/2009 governs the finished product's safety assessment (via the CPSR), labelling, and market placement. However, this doesn't mean cosmetics sit outside REACH entirely it means REACH obligations attach to the substances used to make the product, not the finished formulation as a whole.

Where REACH Actually Touches Your Cosmetic Business

1. Substance Registration by Your Suppliers

If your raw material suppliers manufacture or import chemical substances into the EU above the one-tonne threshold, they are responsible for registering those substances with ECHA. As a cosmetic brand buying finished raw materials, this obligation generally sits upstream with your supplier but it's worth confirming your key suppliers are REACH-compliant, especially when sourcing from outside the EU.

2. Safety Data Sheets (Article 31)

REACH Article 31 is the legal basis requiring your raw material suppliers to provide a Safety Data Sheet for hazardous substances and mixtures. This is the most frequent, practical point of contact between REACH and a cosmetic brand's daily operations every SDS you collect from a supplier exists because of this REACH obligation.

3. Restricted and Banned Substances

REACH Annex XVII restricts or bans certain substances from use in specific applications. While the Cosmetics Regulation has its own, more specific restricted-substance annexes (Annexes II–VI) that typically take precedence for cosmetic formulation, REACH restrictions can still apply where a substance isn't separately addressed under cosmetics law, or where the cosmetics annexes reference REACH classifications directly.

4. The SVHC Candidate List

ECHA maintains a list of Substances of Very High Concern (SVHCs) substances identified as carcinogenic, mutagenic, toxic to reproduction, persistent/bioaccumulative, or otherwise of serious concern. If a raw material you use contains an SVHC above 0.1% by weight, your supplier has a duty to inform you, and you may have downstream communication obligations of your own, particularly if you export or supply articles containing that substance.

5. Microplastics Restrictions

One of the more recent REACH restrictions directly relevant to cosmetics targets intentionally added microplastics, including certain exfoliating beads and film-forming polymers historically used in rinse-off products. This is a clear example of a REACH restriction reaching directly into cosmetic formulation decisions.

REACH vs the Cosmetics Regulation: Which Takes Priority?

In most day-to-day cases, the cosmetics-specific restricted substance annexes govern your formulation decisions, since they were written specifically with cosmetic use in mind and are generally more detailed for that context. REACH becomes most relevant when a substance isn't specifically addressed under the cosmetics annexes, or when an SVHC or restriction applies broadly across all uses.

Practical Scenarios

Scenario 1 — A supplier discloses your fragrance oil contains an SVHC above 0.1%.
Action: request full details from the supplier, check whether the substance is separately restricted under the Cosmetics Regulation, and flag it to your safety assessor for the CPSR review.

Scenario 2 — You're formulating an exfoliating scrub with plastic microbeads.
Action: check current REACH microplastics restrictions before finalising the formula this is a category where REACH directly overrides what might otherwise seem like a straightforward cosmetic ingredient choice.

Scenario 3 — You're importing a raw material from a non-EU supplier for the first time.
Action: confirm the supplier (or your business, if you're the importer of record) has met REACH registration obligations for that substance before bringing it into the EU/UK market at scale.

Common Mistakes Cosmetic Brands Make With REACH

Mistake #1 — Assuming REACH doesn't apply because "cosmetics have their own regulation." The two frameworks overlap; REACH obligations at the raw-material level don't disappear just because the finished product falls under cosmetics law.

Mistake #2 — Not checking the SVHC Candidate List when sourcing new raw materials. This list is updated periodically, so a substance that was fine last year could be added later.

Mistake #3 — Overlooking microplastics restrictions in exfoliating or film-forming ingredients. This is one of the clearest direct REACH-to-cosmetics restrictions, yet frequently missed by newer formulators.

Mistake #4 — Assuming your supplier's REACH registration status has been verified once and doesn't need rechecking. Supplier compliance status can change; periodic checks are good practice, especially for long-term key ingredients.

Practical Checklist

• Confirm key raw material suppliers meet REACH registration obligations, especially for non-EU sourced materials.
• Check new ingredients against the current SVHC Candidate List before finalising a formula.
• Review any exfoliating, film-forming, or particulate ingredients against current microplastics restrictions.
• Cross-check restricted substance status against both REACH Annex XVII and the Cosmetics Regulation's own annexes.
• Flag any SVHC disclosure from a supplier to your safety assessor as part of your CPSR process.

Frequently Asked Questions

Does REACH apply to finished cosmetic products?

Not directly for registration purposes — finished cosmetics are governed primarily by the Cosmetics Regulation. However, REACH still applies to the substances used to manufacture those cosmetics, and to obligations like SDS provision and SVHC disclosure.

What is the SVHC Candidate List and how often does it change?

It's ECHA's list of Substances of Very High Concern, updated periodically (typically a couple of times a year) as new substances are assessed and added. It's worth checking the current list when sourcing new or unfamiliar raw materials.

Am I responsible for my supplier's REACH registration?

The registration obligation sits with the manufacturer or importer of the substance itself. As a cosmetic brand buying finished raw materials from an EU-based supplier, you're generally relying on their compliance rather than registering the substance yourself — but if you import directly from outside the EU/UK in bulk, you may become the importer of record with your own obligations.

Do UK REACH and EU REACH have the same restricted substance list?

They were aligned at the point of UK withdrawal from the EU, but the two frameworks can diverge over time as each authority updates its own restrictions and SVHC list independently.

Does REACH cover natural or plant-derived cosmetic ingredients?

Yes. REACH obligations are based on chemical substance identity and hazard properties, not on whether an ingredient is naturally derived, so natural ingredients are not automatically exempt.

Final Word

REACH rarely requires a cosmetic brand owner to take direct action themselves  most of its obligations sit with your raw material suppliers. But three things are worth owning directly: checking new ingredients against the SVHC Candidate List, staying current on microplastics restrictions, and making sure your safety assessor has visibility of any REACH-related disclosures from your supply chain when preparing your CPSR.

Not sure how REACH affects your specific formula? NestQual prepares CPSRs, PIFs, and full compliance packs for cosmetic brands entering the UK, EU, and global markets including checking your ingredients against current restricted substance and SVHC lists.

Get a CPSR for your product See the Complete Compliance Pack

Sources

1. European Parliament and Council, Regulation (EC) No 1907/2006 (REACH) — eur-lex.europa.eu
2. European Chemicals Agency, Candidate List of Substances of Very High Concern (SVHC) — echa.europa.eu
3. European Parliament and Council, Regulation (EC) No 1223/2009 on cosmetic products — eur-lex.europa.eu
4. Health and Safety Executive (HSE), UK REACH — hse.gov.uk
5. Cosmetic, Toiletry and Perfumery Association (CTPA), Safety of Cosmetics — ctpa.org.uk

This article is for general information and does not constitute legal advice. Always confirm current requirements for your specific product and market with a qualified safety assessor or Responsible Person.