ECHA Publishes Final Report for REF-12 Project – Numerous Violations Found in Imported Goods

Inspections carried out in 2024 as part of the REF-12 project revealed that every third mixture examined violates the provisions of REACH because the ingredients were not registered in accordance with the law. In imported consumer products, the inspectors also found many hazardous substances in concentrations that exceed the permissible limits.

Altogether, the inspectors carried out more than 2,600 checks in 29 countries. The results were sobering. According to the findings, one-third of the mixtures examined lacked registration data for their ingredients. For imported substances, the rate was only 7%. Nonetheless, the ECHA press release indicated that the number of deficiencies was higher than it had been in similar tests in the past.

The problem with costume jewelry

One focus was the investigation of imported jewelry. Analysis revealed high concentrations of heavy metals, including cadmium and lead. The authors acknowledged that they specifically selected problematic goods for their investigations. That’s why the defect rate cannot be used as a reference for product violations in general.

Importers’ Responsibility

Many importers of mixtures do not know what substances a product contains. As a result, they remain completely unaware of their registration obligations. But ignorance does not protect them from the consequences. It is therefore important for inspectors to make importers aware of their obligations. As one example of a possible approach, they recommend demanding transparency from manufacturers and obtaining analysis reports.

Checks and More Checks

Consequently, the enforcement forum will focus on checking imported goods over the next two years. Read more about this in our blog post: REACH-EN-FORCE: 2026/2027 Program Finalized – Focus on Imports and Online Sales.

Don’t take any risks with the safety of your products. We will be happy to answer your questions at sales@kft.de.