The European commission has committed to improve the compliance for imported goods with REACH and CLP obligations with the aid of Customs authorities.

They evaluated the REACH requirements that could be integrated in customs procedures, and started with the integration of REACH Annex XIV – Authorisation list substances in TARIC (Integrated Tariff of the European customs Union) database.  Companies that import an Annex XIV substance should either provide a valid authorisation, or demonstrate being subject to an exemption.

The second phase, Integration of REACH Annex XVII – Restriction list substances in TARIC, has been operational since February 2023. Companies that import products with commodity codes that are subject to REACH import control, need to provide one of the following TARIC codes in their customs declaration:

  • Y106 – Compliance with the REACH restrictions defined in Column 2 of Annex XVII of Regulation (EC) No 1907/2006
    • Substance is restricted and the Importer is in compliance
    • The code Y106 is used when the product contains a substance mentioned in column 1 of Annex XVII and the product is a product referred to in column 2, i.e. it is covered by the restriction. Make sure that the product fulfils the conditions for import mentioned in column 2.
  • Y110 – Exemption from REACH restrictions by virtue of Article 67(1) and 67(2) of Regulation (EC) No 1907/2006
    • Substance is restricted but the use is exempt as per article 67 (1) (2):
      • Scientific Research and Development (SR&D)
      • Product and Process Orientated Research and Development (PPORD) – where specified in the restrictions entry
      • Cosmetic products – where restrictions are imposed due to risks for human health
  • Y113 – Product not subjected to the provisions of Regulation (EC) No 1907/2006 (Annex XVII).
    • The code Y113 is used when the product is not covered by the restrictions according to Annex XVII. The substance may still have other obligations under REACH.

To achieve compliance, we recommend that you start by checking with your customs agent, and reviewing your processes for tracking substances of concern.

H2 can support you with the assessment of your inventory and setting up a process to comply, including bespoke software solutions.

For more information and help with complying, please get in touch.