ECHA Heavy Duty Inspection is coming!

On June 3, 2026, the European Chemicals Agency (ECHA) Enforcement Forum released an official announcement that the EU's new round of joint enforcement project REF-16 has officially finalized its enforcement plan. The project will launch a comprehensive on-site inspection in 2028 and release the final enforcement report in 2029. This round of inspection will focus on strict control of hazardous substance limits for all categories of products, and all foreign trade and production enterprises that layout in the EU market must make compliance preparations in advance.

Note：The image is sourced from the European Chemicals Agency.

According to Article 67 (1) of the REACH regulation, substances, mixtures or articles containing restricted substances in Appendix XVII that do not meet the limit standards are prohibited from being placed on the EU market. The core of this REF-16 law enforcement is to verify the concentration of restricted harmful substances in imported products and industrial mixtures batch by batch, strictly inspect goods that exceed the standard and violate regulations, and comprehensively upgrade law enforcement standards and sampling efforts. Violating enterprises will face penalties such as delisting of goods, port detention, administrative fines, and platform bans.

The two new regulations in this enforcement directly break the inertia of foreign trade compliance in the past, and the risk points are visible to the naked eye. Firstly, cross-border online sales will be fully included in the scope of inspection, and supervision will no longer distinguish between offline bulk shipments and online cross-border retail. Previously, EU REF-8 enforcement data showed that 78% of products sold online in the EU failed REACH restriction inspections, making it a high-risk channel for violations. In the future, ECHA will work with the European Commission and regulatory authorities of member states to regulate major cross-border e-commerce platforms based on the Digital Services Law, ensuring that the compliance threshold for online goods is completely the same as that for offline products.

Secondly, the pilot inspection of special categories will be implemented simultaneously, and special spot checks will be conducted on tattoo ink and permanent beauty cosmetics. Inspectors not only verify whether the hazardous substance threshold of the product is compliant, but also verify whether the foreign language labels, safety labels, and compliance files of the product are complete and standardized. If the labels are non compliant or the information is incomplete, it will also be judged as illegal goods. In addition, chemical additives, coatings, lithium batteries, corrosives, flammable agents, and other 2-9 categories of dangerous goods belong to high-risk inspection categories, and the inspection risks for exporting to Europe are much higher than those for ordinary goods.

At present, the REACH restricted substance list is dynamically updated frequently, and various limit standards are detailed and strict. Many companies are prone to overlook the compliance details of ingredient testing, data filing, and hazardous material transportation throughout the entire process. Especially for hazardous material exports, in addition to meeting product ingredient standards, they also need to match supporting processes such as compliant packaging, maritime declaration, qualification customs declaration, MSDS pre-approval, etc. Any mistake in any link can lead to the obstruction of customs clearance for the entire container of goods.

In response to this round of strict inspections, it is recommended that companies immediately conduct product ingredient self inspections, verify the content of restricted substances, complete the full set of compliance documents for EU customs clearance, and optimize the export supply chain.

Relying on the resources of the Pearl River Delta ports, Guangzhou Xingmei Ship can undertake the full process of booking, warehousing, customs declaration, and door-to-door services for various general dangerous goods, focusing on compliant dangerous goods operations, helping export enterprises simplify processes, reduce inspection probabilities, and easily connect with EU overseas business. If you have any plans for exporting European goods, please feel free to inquire at any time.

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