REACH & CLP compliance services for cosmetic products

For cosmetic brands, compliance extends beyond the finished product to the substances used in its formulation. The EU REACH Regulation (EC 1907/2006) applies to these substances, including those imported as part of finished cosmetics, and establishes registration requirements and substance restrictions. Registration obligations depend on supply-chain roles, annual substance volumes and applicable exemptions.
The CLP Regulation (EC 1272/2008) governs the classification, labelling and packaging of substances and mixtures. Although finished cosmetic products intended for the final user are exempt from CLP, cosmetic raw materials remain within its scope. Importantly, harmonised classifications of ingredients as carcinogenic, mutagenic or toxic to reproduction (CMR) trigger prohibitions on their use in cosmetics, unless specific exceptions apply under the EU Cosmetics Regulation. Monitoring ingredient classifications is therefore essential to maintaining compliant formulations.
Great Britain operates under separate UK REACH and GB CLP frameworks, requiring market-specific compliance checks.
TRC helps you translate these requirements into practical compliance management, connecting ingredient information, supplier documentation and portfolio data to identify your obligations and assess the impact of regulatory changes.

regulation

REACH Regulation (EC) No 1907/2006 & CLP Regulation (EC) No 1272/2008

notification portal

ECHA, REACH-IT / IUCLID

Markets covered

EU, UK

registration threshold

≥ 1 tonne/substance/year

— About reach regulations

REACH Regulation and its impact on cosmetics

REACH complements the EU Cosmetics Regulation by addressing risks beyond the safety of the finished cosmetic product for human use, particularly the environmental impact of its ingredients. Cosmetic businesses must therefore ensure that substances in their products, including those imported into the EU as finished cosmetics, meet applicable REACH registration requirements and substance restrictions, which can affect ingredient selection, sourcing and formulation.

All EU manufacturers, all EU importers or their suppliers of chemical substances have an obligation to submit a registration to the European Chemicals Agency (ECHA) for each substance manufactured or imported per year per company (legal entity) in the EU. The registration obligation applies to volumes per substance and per legal entity exceeding 1000 kg /year. Similar registration obligations apply in Great Britain under UK REACH, with registrations managed by the Health and Safety Executive (HSE).

Note that certain product categories such as medicines, food, feed and biocide active substances are exempted from REACH registration and authorization of substances, because other regulations apply instead.

Substances manufactured or imported into the EU/UK

EU and UK manufacturers and importers must determine whether substances they manufacture or import are subject to REACH registration. The registration threshold generally applies from 1 tonne per substance per legal entity per year, unless an exemption applies. When a substance is not exempted, EU manufacturers and first importers into the EU are responsible to ensure registration of the substance either by themselves or for example by their suppliers.

Substances already registered by suppliers

In most cases, substances have already been registered by manufacturers, suppliers or industry consortia. Companies therefore need to verify the REACH status of their substances and the supporting statements provided by suppliers. Where necessary, access to an existing registration may be obtained through a Letter of Access.

Substances in articles, including packaging

REACH applies not only to substances in product formulations, but also to substances contained in articles. Packaging components, such as bottles, jars, tubes and caps, are articles because their shape, surface or design determines their function more than their chemical composition.

Packaging must comply with applicable substance restrictions under REACH Annex XVII. Where an individual article contains a Candidate List substance of very high concern (SVHC) above 0.1% by weight, supply-chain information obligations apply, and notification to ECHA may also be required. Packaging is therefore an integral part of the overall REACH compliance assessment.

— About CLP regulations

What about CLP?

The CLP Regulation (EC 1272/2008) governs the classification, labelling and packaging of substances and mixtures.

Although finished cosmetic products intended for the final user are exempt from CLP, cosmetic raw materials remain within its scope. Importantly, harmonised classifications of ingredients as carcinogenic, mutagenic or toxic to reproduction (CMR) trigger prohibitions on their use in cosmetics, unless specific exceptions apply under the EU Cosmetics Regulation.

Monitoring ingredient classifications is therefore essential to maintaining compliant formulations.

— REACH & CLP Services —

A clear multi-step approach to REACH/CLP for cosmetic brands

REACH applies to the substances in your cosmetic formulations, including those imported into the EU as part of finished products – not only those supplied as raw materials. Registration requirements depend on your company’s role in the supply chain and the cumulative annual quantity of each substance manufactured or imported by the same legal entity across all relevant products. Compliance therefore requires a portfolio-wide assessment, rather than a separate check of each cosmetic product.

As your portfolio grows, the same substances may appear in multiple formulations sourced from different suppliers and contract manufacturers. Where several EU importers are involved, their respective responsibilities and registration coverage also need to be established. Effective REACH management brings together formulation data, annual volumes and supply-chain documentation to determine which obligations apply and identify any compliance gaps.

The EU Responsible Person (RP) can provide a practical coordination point through its access to product and ingredient documentation. However, REACH registration responsibilities follow the roles of substance manufacturer, importer or appointed Only Representative, not RP status itself.

TRC translates this assessment into a clear, practical compliance plan for your cosmetics portfolio. We support businesses under both EU REACH & CLP and the separate UK REACH & CLP framework applicable in Great Britain. Our services include:

Substance identification and volume calculations. We map the substances in your cosmetic formulations and raw materials, identify the relevant suppliers and importers, and calculate cumulative annual quantities manufactured or imported per legal entity.
Verification of REACH status and supply-chain coverage. We assess applicable registration requirements, exemptions and restrictions, review supplier REACH declarations, and verify registration coverage for the relevant substances, uses and import arrangements.
REACH compliance documentation. We prepare REACH assessment reports and, where supported by the findings, compliance statements documenting the status of your portfolio and any outstanding actions.
Advice on resolving REACH compliance gaps. We help you evaluate practical options, including registration, reformulation or alternative sourcing with appropriate REACH coverage.
Assessment of REACH registration options and costs. Where registration is required, we contact relevant consortia or lead registrants to explore participation in an existing joint submission, including access to data through a Letter of Access, anticipated timelines and costs.
Referral for specialist REACH registration services. Where a new registration is necessary, we explain the next steps and refer you to specialised service providers for dossier preparation and submission.
CLP classification review and impact assessment. We review ingredient hazard classifications and relevant classification updates, assess their consequences for cosmetic ingredient compliance, and advise on any necessary changes to formulations or sourcing.

— PRIMS

REACH backed by PRIMS software

TRC manages REACH compliance using PRIMS, our proprietary compliance and safety platform. PRIMS connects finished products, formulations and raw materials down to substance level, allowing us to identify substances subject to REACH requirements and trace where they occur across your portfolio.

REACH dashboards, SVHC documentation, where-used analyses and current and future compliance assessments help us identify affected products and determine where further assessment, documentation or action is required. Regulatory changes can be assessed across the portfolio without repeatedly reviewing the same substance or raw material.