ECHA Enforcement Forum: Non-Compliance Continues in Imported Chemicals and Products — Time for "Proper Pre-Assessment" for KKDİK
ECHA Enforcement Forum: Non-Compliance Continues in Imported Chemicals and Products — Time for "Proper Pre-Assessment" for KKDİK
The REF-12 enforcement project conducted in the EU revealed persistent non-compliance in imported substances/mixtures and consumer products. ECHA announcement highlights that "one-third of substances in mixtures lack REACH registration".
Scope of enforcement
29 countries conducted 2,603 checks throughout 2024.
Checks covered REACH registration, restrictions, and authorisation obligations.
Most critical findings (clear and measurable)
1) Registration
Non-compliance rate for substances imported in mixtures: 32%
If the substance is imported alone, non-compliance rate: 7%
2) Restrictions
Non-compliance rate for restricted substances checked: 16%
Focus of checks was particularly on jewelry, also toys and textiles.
3) Authorisation
21 checks examined authorisation obligations; in some cases authorisation was missing/expired.
Critical reading for Turkey (especially for manufacturers selling to the EU)
The REF-12 report indicates that Turkey-origin substances ranked among the top in the origin distribution of checked substances, and a high rate was seen for Turkey in the "country-based" non-compliance calculation (this rate is calculated based on the enforcement sample).
What does this mean?
EU customers and importers will ask suppliers **"is there registration/compliance evidence?"** before "do you have an SDS?".
Manufacturers/suppliers who cannot give a clear answer to "what's in the mixture?" may be classified as high-risk suppliers in the EU.
Pier Compliance note: Same reflex necessary in KKDİK process in Turkey
The core message of the EU results is very clear: Compliance is not filling forms; it is correct substance identity + correct role + correct evidence chain.
In KKDİK too, manufacturers/importers must conduct pre-assessment with the same discipline before import/supply. Otherwise, "correction" afterward is often costly and delaying.
Clear call to manufacturers: Check today (10-minute pre-screening)
If 3+ of the following apply to you, take the process seriously:
- CAS/EC verification of components in your mixtures is not clear.
- "Who is the registration responsible?" (manufacturer/importer/OR) chain is unclear.
- SDS/label exists but REACH/KKDİK scope–tonnage–exemption analysis has not been done.
- Restricted substance risk is not managed in product groups like jewelry/toys/textiles.
- Evidence file (traceable records) you can show to customers/inspection is missing.
What do we recommend? (5 most practical steps)
1. Substance identity verification (component list, CAS/EC, UVCB check)
2. Role and obligation map (who takes on what?)
3. Registration/restriction/authorisation screening (by product and component)
4. SDS/label consistency check (including SEA/CLP compliance)
5. Inspection-ready evidence package (single folder: registration evidence, supplier declaration, traceability)
Sources
- ECHA Enforcement Forum – REF-12 Project Report (2,603 checks; 32% in mixtures, 7% in single substance; 16% in restrictions; focus: jewelry/toys/textiles; origin-based table).
- ECHA press release summary text (emphasis on "1/3 registration missing" in mixture substances).
- Mayer Brown – Europe Daily News (ECHA/NR/25/43 reference).
**Warning:** This content is for informational purposes only; it is not legal advice.