REACH Compliance Guide for Polyurethane Chemical Imports from China: What Every EU Buyer Must Know in 2026

1. What Is REACH and Why Does It Matter for PU Chemical Importers?

REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) — EU Regulation EC 1907/2006 — is the world's most comprehensive chemical regulation. It applies to any chemical substance manufactured in or imported into the EU in quantities of 1 metric ton or more per year.

Who bears responsibility?

Under REACH, the importer (the EU-based company receiving the goods) is the legal registrant — not the Chinese exporter. This means:

• If you import PMDI from China under your company's name, YOU are responsible for REACH registration.
• If your Chinese supplier (like DOBO Chemical) has appointed an Only Representative (OR) in the EU, the OR handles registration on behalf of the non-EU manufacturer.
• If neither route is completed, the import is illegal.

2. The Diisocyanate Restriction (REACH Annex XVII, Entry 74) — What Changed in 2023

This is the single most impactful regulatory change for the PU industry in recent years:

Practical impact for importers:

• Before ordering MDI or TDI from China, ensure your staff (and your customers' staff, if you resell) complete the training
• Training is available through ISOPA (European Diisocyanate & Polyol Producers Association) and national PU associations — typically online, 1–2 hours, available in 20+ languages
• DOBO Chemical can advise on the correct documentation to include with your shipments

Diisocyanates covered by the restriction:

• MDI (CAS 101-68-8), PMDI (CAS 9016-87-9), Modified MDI
• TDI (CAS 584-84-9, 91-08-7, 26471-62-5)
• HDI (CAS 822-06-0) and its oligomers
• IPDI (CAS 4098-71-9)
• HMDI (CAS 5124-30-1)

3. REACH Registration Process — Step by Step for Importers

Step 1: Determine Your Registration Obligation

Calculate your annual import volume (metric tons per substance per year):

• 1–10 tonnes/year: Full registration with basic dataset
• 10–100 tonnes/year: Full registration + extended SDS
• 100–1000 tonnes/year: Full registration + Chemical Safety Report (CSR)
• >1000 tonnes/year: Full registration + CSR + exposure scenarios

Step 2: Check If the Substance Is Already Registered

Before initiating a new registration, check ECHA's database to see if your substance and tonnage band are already covered.

Step 3: Join a SIEF (Substance Information Exchange Forum)

If a new registration is needed, you must join the SIEF for your substance. SIEF members share toxicological and ecotoxicological data (to avoid duplicate animal testing) and split the cost of the joint registration dossier.

Step 4: Prepare and Submit the Registration Dossier

The dossier is submitted via IUCLID 6 to ECHA and includes:

• Substance identity (CAS, name, composition, impurities)
• Physicochemical properties
• Toxicological and ecotoxicological data
• Classification and labeling (CLP)
• Guidance on safe use
• Exposure scenarios (for >10 tonnes/year)
• Chemical Safety Report (for >10 tonnes/year)

Step 5: Pay the Registration Fee

ECHA fees depend on company size (SME discounts apply) and tonnage band. For a medium-sized importer registering 10–100 tonnes of a new substance, expect fees of approximately €3,000–12,000 (2026 rates, excluding data-sharing costs within the SIEF).

4. Only Representative (OR) — The Alternative Route

If you don't want to register substances yourself, you can ask your non-EU supplier to appoint an Only Representative in the EU. The OR handles registration on behalf of the non-EU manufacturer. Your company is then treated as a "downstream user" rather than an "importer," which significantly reduces your regulatory burden.

How the OR model works:

1. DOBO Chemical appoints an EU-based Only Representative
2. The OR registers the substance with ECHA
3. Your company (the EU buyer) is listed as a downstream user
4. The OR provides you with a registration number and exposure scenarios
5. Your obligations are limited to: following the exposure scenarios, completing diisocyanate training (if applicable), and not using the substance outside authorized uses

OR costs:

Annual fees vary by OR service provider, tonnage band, and substance complexity. Budget approximately €2,000–10,000 per substance per year for a typical OR arrangement.

5. SVHC Screening and Authorization

Substances of Very High Concern (SVHC) are chemicals with serious health or environmental hazards — carcinogenic, mutagenic, reprotoxic (CMR), persistent, bioaccumulative and toxic (PBT), or of equivalent concern.

For PU chemicals, the key SVHC watchlist includes:

• Certain phthalate plasticizers (DOP/DEHP, DBP, BBP, DIBP — already restricted)
• Certain amine catalysts under review
• Cyclopentane (blowing agent) — currently not SVHC-listed but under scrutiny due to VOC emissions

Action for importers:

• Screen every substance you import against the current ECHA SVHC Candidate List (updated twice yearly, in January and July)
• If importing articles (finished goods) containing >0.1% w/w of an SVHC, you must provide information to customers within 45 days upon request
• Communication obligations increase if the SVHC is also on the Authorization List (Annex XIV)

6. CLP Regulation — Classification, Labeling, and Packaging

The CLP Regulation (EC 1272/2008) implements the UN Globally Harmonized System (GHS) in the EU. All PU chemicals imported into the EU must be classified and labeled according to CLP.

Key labeling requirements for common PU chemicals:

Practical labeling checklist for importers:

• Product identifier (chemical name and CAS number) in the official EU language of the destination country
• Hazard pictograms (GHS diamond symbols)
• Signal word (Danger or Warning)
• Hazard statements (H-statements) and precautionary statements (P-statements)
• Supplier identification (your EU company name, address, phone)
• Nominal quantity
• UFI code (Unique Formula Identifier) for hazardous mixtures — required since January 2025

All DOBO Chemical shipments include CLP-compliant labeling in English. EU-language labeling can be arranged upon request.

7. Safety Data Sheet (SDS) Requirements

Every chemical shipment into the EU must be accompanied by a Safety Data Sheet (SDS) that complies with REACH Annex II (as amended by Regulation EU 2020/878).

The 16-section SDS checklist:

8. Customs Clearance — Documentation Required

When your shipment arrives at an EU port (Rotterdam, Hamburg, Antwerp, Gdansk, etc.), customs authorities may request:

Mandatory documents:

• Commercial Invoice (with HS code, country of origin, declared value)
• Packing List
• Bill of Lading or Air Waybill
• REACH Registration Number (or OR confirmation letter)
• Safety Data Sheet (SDS) in the official language of the importing country
• CLP-compliant label copy
• Diisocyanate training certificate (for MDI/TDI shipments)

Additional documents that may be requested:

• Certificate of Analysis (COA)
• Certificate of Origin (Form A or EUR.1 for preferential duty rates)
• TSCA compliance statement (only if transshipping through the US)
• Dual-use export control declaration (rare for basic PU chemicals; relevant for specialty isocyanates used in defense applications)

9. Practical Compliance Checklist for 2026

Before placing your next PU chemical order from China, verify:

10. Frequently Asked Questions

Conclusion: REACH Compliance Is Your Competitive Advantage

For serious EU importers, REACH compliance isn't just a legal requirement — it's a competitive advantage. Buyers who can demonstrate full regulatory compliance win contracts over suppliers who treat it as an afterthought. With diisocyanate regulations tightening and enforcement increasing, the gap between compliant and non-compliant importers will only widen.

At DOBO Chemical, we've built our supply chain around REACH-compliant manufacturers. Every product we export to the EU is supported by registration documentation, compliant SDS, and the regulatory expertise to guide your import process. Whether you need container-load quantities of PM200 or a trial shipment of specialty polyols for a new formulation, we ensure your documentation is complete before your cargo ships.