REACH Enforcement: ECHA Launches REF-16 Project on Restricted Substances in Products

On 3 June 2026, ECHA's Enforcement Forum published its next enforcement priorities. The central project, REF-16, will check whether products and mixtures sold on the EU market comply with restrictions on hazardous substances under EU chemicals legislation. For companies that manufacture, import, distribute, or sell products online in the EU, this is the time to review product-level compliance before inspections begin.

What REF-16 will check

REF-16 will focus on compliance with restrictions listed in Annex XVII to the REACH Regulation. Inspectors will check whether restricted hazardous substances in products are below the applicable legal limits. The project covers both physical and online sales channels, with specific attention to:

• Online marketplaces
• Cross-border e-commerce platforms
• Company-owned websites
• Digital storefronts operated by distributors or retailers

The Enforcement Forum will cooperate with the European Commission and national authorities to explore how findings from online sales inspections can support enforcement under the Digital Services Act, particularly where online platforms are used to market non-compliant products. Inspections are planned for 2028, with the enforcement report expected in 2029.

Who is affected

The scope of REF-16 is broad. Even if a product is manufactured outside the EU, it can still be checked once it is placed on the EU market by an importer, distributor, or online seller. Previous ECHA enforcement projects found non-compliance rates of around 20% or more in checked products.

The product types most likely to be checked include consumer goods, coatings, plastic products, textiles, adhesives, inks, and chemical mixtures, as these are areas where non-compliance with REACH Annex XVII restrictions has been identified in previous projects.

What your business should do now

Inspections under REF-16 do not start until 2028, but preparation should start now. Key steps include:

• Screening products and mixtures against the relevant entries in REACH Annex XVII and checking that restricted substances are below applicable limits
• Reviewing supplier declarations, testing reports, and formulation data, and not relying on general supplier statements alone for higher-risk products
• Checking that product information shown online, including on marketplace listings and distributor pages, is consistent with labels, safety data sheets, and approved uses
• For companies with REACH registration obligations: monitoring changes to CLP harmonised classifications and updating registration dossiers where required

Source: ECHA Enforcement Forum