REACH Annex XVII Compliance: Deadlines, Testing & Evidence

Last updated: June 2026

REACH Annex XVII compliance is one of the most important chemical compliance obligations for companies placing products, mixtures, materials or articles on the EU/EEA market. For manufacturers, importers, retailers, private-label brands, distributors and product compliance teams, Annex XVII is not just a restricted substances list. It is a legal restriction framework that can ban or limit the manufacture, placing on the market or use of certain hazardous substances in specific products, materials, mixtures or applications.

The challenge for companies is practical: Which REACH Annex XVII restrictions apply to my products? Which suppliers are affected? Do I need testing? What evidence should I collect? How do I prove compliance during customer audits or authority inspections?

This guide explains the latest REACH Annex XVII updates, deadlines, affected product categories, testing strategy, supplier evidence requirements and how ComplyMarket product compliance software can help companies manage Annex XVII compliance in a structured, traceable and audit-ready way.

REACH Annex XVII is the EU list of restrictions on the manufacture, placing on the market and use of certain hazardous substances, mixtures and articles. Each restriction entry defines the substance or substance group, the product or material scope, the concentration limit or condition, the restricted use, and any exemptions or transition periods.

A REACH Annex XVII restriction may apply to:

• A substance on its own.
• A substance in a mixture.
• A substance in an article.
• A specific product category, such as textiles, leather, cosmetics, toys, food-contact paper, firefighting foams, coatings, adhesives or industrial articles.
• A specific use, such as consumer use, professional use, industrial use, dry cleaning, firefighting training or cosmetic application.
• A specific concentration threshold, such as percentage by weight, mg/kg, ppb or mg/L.
• A specific exposure route, such as skin contact, inhalation, environmental release or worker exposure.

The most important point for compliance teams is that Annex XVII must be assessed entry by entry. A generic “REACH compliant” supplier statement is not enough unless it is supported by evidence that matches the exact restriction conditions.

For example, some restrictions apply to the whole mixture, while others apply to a homogeneous material, a finished article, a product category, a use condition, a professional-user scenario or a consumer-use scenario. This is why REACH Annex XVII compliance requires legal screening, material mapping, supplier data, SDS review, testing evidence and change control.

Recent REACH Annex XVII updates show a clear regulatory trend: the EU is increasing restrictions on PFAS, persistent substances, CMR substances, microplastics, worker-exposure substances and hazardous substances in consumer and professional-use articles.

The following updates are especially important for companies selling products, materials, mixtures or components into the EU market.

Synthetic polymer microparticles — Regulation (EU) 2026/1168

Regulation (EU) 2026/1168 amends Entry 78 of Annex XVII for synthetic polymer microparticles. It clarifies derogations for medicinal products, veterinary medicinal products and product and process-oriented research and development, also known as PPORD, in quantities of 1 tonne per year or less. It also clarifies the solid-matrix derogation, specifying that the intended end use must last one year or longer.

Key dates:

• Some amendments apply retroactively from 17 October 2023.
• The solid-matrix clarification applies from 22 June 2028.

Why it matters:
Companies using synthetic polymer microparticles should reassess whether their products rely on the correct derogation and whether information, labelling, reporting or reformulation duties apply.

2,4-dinitrotoluene in articles — Regulation (EU) 2026/859

Regulation (EU) 2026/859 adds Entry 83 for 2,4-dinitrotoluene, also known as 2,4-DNT, in articles. After 10 May 2027, 2,4-DNT must not be placed on the market or used as a substance in articles for professional users or the general public at a concentration equal to or greater than 0.1% by weight.

Key dates:

• General application date: 10 May 2027.
• Certain motor vehicle applications, including micro gas generators for seat belt pre-tensioners and bonnet actuators, and spare parts, have a later application date of 11 May 2029.

Why it matters:
Article suppliers, automotive suppliers, industrial article manufacturers and importers should review material-level composition data, especially for articles supplied to professional users or consumers.

PFAS in firefighting foams — Regulation (EU) 2025/1988

Regulation (EU) 2025/1988 adds Entry 82 for PFAS in firefighting foams. The general restriction sets a concentration limit of 1 mg/L for the sum of all PFAS in firefighting foams from 23 October 2030, with several earlier and later transition periods for specific uses.

Key dates and duties include:

• General restriction from 23 October 2030.
• Certain portable fire extinguisher placing-on-the-market derogations until 23 October 2026 or 23 April 2027, depending on the foam type.
• Certain use derogations until 23 April 2027, 31 December 2030 or 23 October 2035, depending on the application.
• From 23 October 2026, certain users must establish a PFAS-containing firefighting foams management plan.
• From 23 October 2026, labelling duties apply for firefighting foams, unused foam stocks and PFAS-containing waste where relevant thresholds are met.

Why it matters:
Firefighting foam compliance is not only a product-substitution issue. Companies may need inventory records, stock visibility, labelling, waste treatment documentation, management plans, use restrictions and substitution strategies.

CMR substances — Regulation (EU) 2025/1731

Regulation (EU) 2025/1731 updates Annex XVII Appendices 2, 4 and 6 to reflect newly classified carcinogenic, mutagenic or reproductive toxic substances, known as CMR substances, under CLP.

Key date:

• The relevant Annex XVII updates apply from 1 September 2025.

Why it matters:
Companies supplying substances or mixtures to the general public should review whether newly classified CMR category 1B substances are present above applicable limits. This is especially important for paints, coatings, adhesives, inks, cleaning agents, chemical mixtures, hobby products and consumer formulations.

DMAC and NEP — Regulation (EU) 2025/1090

Regulation (EU) 2025/1090 adds Entries 80 and 81 for N,N-dimethylacetamide, known as DMAC, and 1-ethylpyrrolidin-2-one, known as NEP. These are dipolar aprotic solvents used in several industrial and professional applications.

Key dates:

• From 23 December 2026, substances or mixtures containing DMAC or NEP at 0.3% or more must meet specific safety data sheet, chemical safety report and worker-exposure control requirements.
• For DMAC used as a solvent in the production of man-made fibres, the relevant obligations apply from 23 June 2029.

Why it matters:
Manufacturers, importers and downstream users must ensure SDS, chemical safety reports, DNEL values, operational conditions and worker-exposure controls are updated and documented.

PAHs in clay targets — Regulation (EU) 2025/660

Regulation (EU) 2025/660 adds a new PAH restriction for clay targets used in shooting.

Key date and limit:

• From 22 April 2026, listed PAHs must not be placed on the market or used in clay targets for shooting if the sum of all listed PAHs exceeds 50 mg/kg, equal to 0.005% by dry mass.

Why it matters:
Sports goods suppliers, shooting-range operators, clay target manufacturers and importers should review binder composition, supplier evidence and test reports.

PFHxA, salts and related substances — Regulation (EU) 2024/2462

Regulation (EU) 2024/2462 adds Entry 79 for PFHxA, its salts and PFHxA-related substances.

Key limits and dates:

• From 10 October 2026, restrictions apply at 25 ppb for the sum of PFHxA and its salts, or 1,000 ppb for the sum of PFHxA-related substances, measured in homogeneous material, for several product categories.
• Affected product categories include textiles, leather, furs and hides in clothing and related accessories for the general public, footwear for the general public, paper and cardboard used as food-contact materials, mixtures for the general public and cosmetics.
• From 10 October 2027, the restriction extends to certain other textiles, leather, furs and hides for the general public.
• From 10 April 2026, restrictions apply to certain firefighting foams used for training, testing and public fire services.
• From 10 October 2029, restrictions apply to firefighting foams and concentrates for civil aviation.

Why it matters:
This update is highly relevant for textiles, outdoor apparel, footwear, handbags, food-contact packaging, cosmetics, consumer mixtures and firefighting foam supply chains.

D4, D5 and D6 siloxanes — Regulation (EU) 2024/1328

Regulation (EU) 2024/1328 replaces and expands Entry 70 for D4, D5 and D6 siloxanes.

Key dates and conditions:

• After 6 June 2026, D4, D5 and D6 must not be placed on the market as substances, constituents of other substances or in mixtures at a concentration equal to or greater than 0.1% by weight of the respective substance.
• D4, D5 and D6 must not be used as solvents for dry cleaning textiles, leather and fur after 6 June 2026.
• For cosmetic products other than wash-off cosmetics, the restriction applies after 6 June 2027.
• For certain medical devices, in vitro diagnostic devices, medicinal products and veterinary medicinal products, later dates apply.

Why it matters:
Cosmetics, silicone polymers, dry cleaning, medical devices, adhesives, sealants, coatings and industrial silicone supply chains should review formulation data, residue levels, derogations and transition periods.

Recent REACH Annex XVII updates are especially relevant for companies selling finished products, materials, mixtures or components into the EU market. The compliance impact is not limited to chemical manufacturers. It affects brands, importers, retailers, distributors, private-label sellers, component suppliers and manufacturers that rely on complex supply chains.

For product compliance teams, the key question is not only: “Does this substance appear in our product?” The better question is: “Does this restriction apply to this material, use, concentration, customer group, deadline or exemption?”

Textiles, leather and footwear

Textiles, leather, furs, hides, accessories and footwear are among the product categories most affected by recent Annex XVII updates, especially because PFAS-based chemistries have historically been used for water resistance, oil repellency, stain resistance and performance finishes.

The PFHxA restriction is especially relevant for companies selling clothing, outdoor apparel, sportswear, uniforms, bags, accessories, leather goods, footwear and coated textile products to the general public in the EU.

Compliance teams should review:

• Water-repellent finishes.
• Oil-resistant or stain-resistant treatments.
• Coated fabrics and laminated textiles.
• Membranes and performance layers.
• Leather surface treatments.
• Adhesives, printed logos and coated trims.
• Supplier claims such as “waterproof,” “oil-resistant,” “easy-clean” or “high-performance finish.”

The main risk is often not the base fabric or leather itself, but the treatment or coating applied by upstream suppliers. Companies should collect material-specific supplier declarations, request PFAS-free or fluorine-free finish information, and test high-risk treated materials where supplier evidence is weak.

Firefighting foams and fire safety equipment

Firefighting foams are one of the most directly affected categories under recent PFAS restrictions. This is highly relevant for foam manufacturers, distributors, fire brigades, airports, ports, offshore facilities, refineries, petrochemical sites, defence operators, industrial facilities and building operators maintaining fire suppression systems.

The compliance challenge goes beyond replacing a foam formulation. Companies may need to:

• Identify PFAS-containing foam stocks.
• Check concentration limits.
• Review transition periods.
• Label foam stocks and PFAS-containing waste.
• Prepare site-specific management plans.
• Control use during training, testing and emergency response.
• Document waste collection and treatment.
• Plan substitution to fluorine-free alternatives.

Firefighting foam compliance requires coordination between procurement, EHS, legal, maintenance, emergency response and product compliance teams.

Cosmetics and personal care products

Cosmetics and personal care products face increasing Annex XVII pressure because restricted substances may appear as ingredients, impurities, processing residues, film-formers, fragrance carriers, texture agents or performance additives.

Relevant Annex XVII topics include:

• D4, D5 and D6 siloxanes.
• Synthetic polymer microparticles.
• PFHxA, salts and related substances.
• PFAS-based performance ingredients.
• Formulation residues and impurities.

Cosmetics companies should review products with claims such as “long-wear,” “waterproof,” “transfer-resistant,” “film-forming,” “high-performance” or “water-resistant.” They should also assess intentionally added polymeric particles, encapsulated ingredients, glitter, exfoliating particles and film-forming polymers.

Recommended evidence includes full formulation data, supplier declarations, ingredient technical functions, SDS where applicable, derogation assessments, reformulation records and test reports for high-risk substances.

Medical devices and medicinal products

Medical devices, in vitro diagnostic devices, medicinal products and veterinary medicinal products may be affected by Annex XVII restrictions, but several restrictions include specific derogations or later application dates for healthcare-related uses.

This does not mean these products can be ignored. It means companies must document why the product qualifies for the relevant exemption, derogation or transition period.

Medical and healthcare products may contain restricted substances in:

• Polymers and tubing.
• Coatings and lubricants.
• Adhesives and seals.
• Silicone components.
• Diagnostic materials.
• Packaging.
• Drug-delivery systems.
• Electronic components.

The key risk is weak documentation. If a company relies on a derogation, it should be able to show the product scope, legal basis, intended use, material function and evidence supporting the exemption.

Automotive and industrial articles

Automotive and industrial articles are increasingly affected by Annex XVII because complex products contain many hidden chemical risk points across components, coatings, elastomers, foams, textiles, adhesives and safety systems.

The 2,4-DNT restriction is especially relevant for articles supplied to professional users or consumers, including certain automotive safety-related applications with specific transition timing.

Automotive and industrial suppliers should review:

• Seat belt pre-tensioner systems.
• Bonnet actuators.
• Micro gas generators.
• Spare parts.
• Rubber and elastomeric components.
• Seals and gaskets.
• Coatings and adhesives.
• Interior trim and foams.
• Textiles and treated surfaces.
• Imported assemblies and subcomponents.

The challenge is supply-chain depth. A Tier 1 supplier may not have full visibility into Tier 2 or Tier 3 chemical composition. This makes structured supplier declarations, material mapping and change control essential.

Coatings, adhesives, inks and chemical mixtures

Coatings, adhesives, sealants, inks, paints, cleaning agents, processing aids and other chemical mixtures are heavily affected by Annex XVII because restrictions can apply directly to substances and mixtures.

Recent updates on DMAC and NEP are especially important for companies using or supplying solvents in industrial processes, coatings, polymers, fibre production, electronics, adhesives and speciality chemical applications.

Compliance teams should review:

• SDS quality and completeness.
• Formulation data.
• Concentration ranges.
• CMR classifications.
• DNEL values.
• Exposure scenarios.
• Worker-exposure controls.
• Operational conditions.
• Supplier declarations and formulation changes.

Finished product testing may not always be enough. For mixtures, companies often need formulation-level evidence and supplier composition data.

Food-contact paper, cardboard and packaging

Food-contact paper, cardboard and packaging should be reviewed because PFHxA restrictions can affect paper and board used as food-contact materials.

High-risk applications may include:

• Grease-resistant paper.
• Water-resistant paper.
• Oil-resistant packaging.
• Fast-food packaging.
• Bakery packaging.
• Takeaway containers.
• Wrappers and paper bags.
• Coated or barrier-treated boards.

The compliance risk is often linked to surface treatment or barrier chemistry, not the base paper itself. Packaging suppliers and brand owners should request treatment chemistry information, food-contact declarations, PFAS test reports and coating supplier documentation.

Toys, childcare products and consumer goods

Toys, childcare products and consumer goods often face higher scrutiny because they may involve direct skin contact, oral exposure, use by children or repeated consumer exposure.

Annex XVII restrictions may affect:

• Plastics.
• Rubber.
• Coatings.
• Paints.
• Textiles.
• Adhesives.
• Foams.
• Leather.
• Printed materials.
• Metal parts.

Importers and private-label sellers are especially exposed because they often rely on third-party factories and may not have direct formulation control. Customer audits and market surveillance authorities increasingly expect structured evidence, not only supplier promises.

Electronics, electrical equipment and components

Electronics and electrical equipment can be affected by Annex XVII even if companies already manage RoHS, POPs or SCIP obligations. REACH Annex XVII compliance is separate from RoHS and must be screened independently.

Potential risk areas include:

• Plastics and rubber.
• Cables and connectors.
• Coatings and conformal coatings.
• Adhesives and sealants.
• Inks and labels.
• Battery-related materials.
• Cleaning agents and process chemicals.
• Gaskets and treated surfaces.

The main mistake is assuming that RoHS compliance automatically proves Annex XVII compliance. It does not. Annex XVII covers a broader set of chemical restrictions across substances, mixtures and articles.

To know whether your products are affected by REACH Annex XVII, companies need a structured applicability assessment. The process should connect legal requirements with actual product data, supplier information and material composition.

Start by asking these questions:

1- Do you place products, mixtures, components or materials on the EU/EEA market?
If yes, Annex XVII may apply.

2- Are your products articles, mixtures, substances or combinations of these?
The restriction scope depends on the legal wording of each Annex XVII entry.

3- Which product categories do you sell?
Textiles, leather, footwear, cosmetics, packaging, toys, electronics, firefighting foams, coatings, adhesives, industrial articles and chemical mixtures may have specific risk areas.

4- Which materials and substances are present?
Review BOMs, formulations, material declarations, SDS, supplier declarations and test reports.

5- Are there high-risk treatments or functions?
Water resistance, oil repellency, stain resistance, flame retardancy, flexibility, pigmentation, coating performance and solvent use may indicate chemical compliance risks.

6- Are your suppliers giving entry-specific evidence?
A generic REACH statement is weaker than a declaration referencing the exact Annex XVII entry, substance group, limit, material and product scope.

7- Are you relying on exemptions or transition periods?
If yes, document the legal basis, product scope and evidence supporting the exemption.

8- Have suppliers, materials or formulations changed?
A previously compliant product may need reassessment after a supplier change, formulation update, new coating, recycled-content change or production relocation.

A practical Annex XVII screening should map each product family to relevant materials, supplier sources, applicable entries, concentration thresholds, exemptions, test evidence and compliance decisions.

A “REACH compliant” supplier letter is rarely enough on its own. Good Annex XVII evidence should be specific, current, traceable and linked to the exact legal requirement.

An audit-ready Annex XVII evidence pack should include:

• Product name, SKU, model, product family or article reference.
• EU market role, such as manufacturer, importer, distributor or brand owner.
• BOM, material or formulation mapping.
• Supplier list and supplier contact details.
• Applicable Annex XVII entries and screening rationale.
• Supplier declarations referencing the exact substance, entry, threshold and material scope.
• Safety Data Sheets for substances and mixtures.
• Composition data or formulation disclosure where needed.
• Laboratory test reports for high-risk materials or uncertain supplier data.
• Exemption or derogation justification where used.
• Labels, warnings or instructions where required.
• Change-control records for materials, suppliers and formulations.
• Nonconformance and corrective action records.
• Version history showing when evidence was collected, reviewed and approved.

The strongest evidence connects six things clearly:

Product → Material → Supplier → Restriction → Evidence → Compliance decision

This traceability is what customers, auditors and market surveillance authorities usually expect when they ask for proof of REACH Annex XVII compliance.

REACH Annex XVII does not create one universal testing requirement for every product. Testing should be risk-based and aligned with the specific restriction entry, product type, material and supplier evidence available.

Testing is usually required or strongly recommended when:

• Supplier declarations are generic, outdated or not entry-specific.
• The product contains high-risk materials such as soft PVC, rubber, coated textiles, leather, pigments, adhesives, foams, recycled plastic or surface-treated materials.
• The product is imported from a high-risk or unknown supply chain.
• The restriction has a precise concentration limit and the company lacks reliable composition data.
• The product is intended for children, skin contact, food contact, consumer use or prolonged exposure.
• There has been a supplier, material, formulation, pigment, coating or manufacturing-process change.
• Customer contracts, retailers or authorities require analytical evidence.
• The product claim suggests chemical treatment, such as waterproof, stain-resistant, oil-resistant, flame-retardant or long-lasting.
• Supplier documentation conflicts with known material risk.

Testing may not be necessary for every low-risk product if the company has strong supplier evidence, full formulation data, reliable SDS information and a documented applicability assessment. However, for high-risk materials and restricted substances with strict concentration limits, laboratory testing is often the most defensible proof.

A strong testing plan should define:

• The product or material tested.
• The specific Annex XVII entry.
• The legal limit.
• The test method.
• The sampling logic.
• The batch, supplier or SKU coverage.
• The laboratory used.
• The result and decision.
• How the result applies to related variants or product families.

Many companies fail Annex XVII compliance not because they ignore REACH, but because their process is too generic or too dependent on supplier promises.

Common mistakes include:

Treating REACH SVHC and Annex XVII as the same thing

The REACH Candidate List and Annex XVII are different obligations. A product can be SVHC-compliant and still fail an Annex XVII restriction if it contains a restricted substance above the allowed limit or in a restricted use.

Relying on generic supplier declarations

A declaration that simply says “REACH compliant” does not prove compliance with a specific Annex XVII entry. Compliance teams should request declarations that mention the exact restriction, substance, threshold, material and product scope.

Screening only by CAS number

Some Annex XVII entries cover groups of substances, related substances, salts, polymers, mixtures or product uses. CAS-based screening alone may miss relevant restrictions.

Applying the wrong concentration basis

Some limits apply to the whole mixture, while others apply to homogeneous material, dry mass, article concentration or specific release conditions. Applying the wrong basis can lead to false compliance conclusions.

Missing transition dates and derogations

Many recent restrictions include phased deadlines, sector-specific derogations or delayed application dates. Missing these dates can create avoidable compliance gaps.

Testing only the finished product

The restricted substance may be concentrated in a coating, adhesive, finish, pigment, membrane or plasticiser. Testing the finished product without material-level logic may not provide reliable evidence.

Forgetting imported articles

Imported articles placed on the EU market can be subject to Annex XVII restrictions. Importers and private-label sellers need supplier evidence and testing strategies even when manufacturing happens outside the EU.

Not reassessing after changes

Compliance should be reviewed after supplier changes, formulation changes, material substitutions, recycled-content changes, production relocation or new product claims.

Keeping evidence that cannot be traced

A test report is weak if it cannot be linked to the current product, material, supplier, batch or restriction entry.

Use this practical checklist to reduce compliance risk and prepare for customer or authority requests.

1. Map your products and materials

Identify all EU/EEA products, SKUs, variants, components, materials, coatings, adhesives, inks, additives and supplier sources.

2. Classify your product type

Determine whether each item is a substance, mixture, article or combination of these. This affects which Annex XVII entries may apply.

3. Screen against relevant Annex XVII entries

Screen by substance, substance group, material, product category, use, customer type, exposure route, concentration threshold and deadline.

4. Prioritise high-risk product categories

Give priority to textiles, leather, footwear, cosmetics, firefighting foams, food-contact packaging, toys, electronics, coatings, adhesives, inks, chemical mixtures, automotive components and imported articles.

5. Collect supplier declarations

Request supplier declarations that are specific to the relevant Annex XVII entry, material, substance group, concentration threshold and product scope.

6. Review SDS and formulation data

For substances and mixtures, check classification, ingredients, concentration ranges, exposure scenarios, DNELs and operational conditions.

7. Identify where testing is needed

Use risk-based testing when supplier evidence is weak, materials are high risk, concentration limits are strict, or customers require analytical proof.

8. Document exemptions and derogations

If you rely on an exemption, keep a written justification explaining why the product fits the legal wording.

9. Control supplier and material changes

Require approval before supplier changes, formulation updates, coating substitutions, recycled-content changes or manufacturing-process changes.

10. Track deadlines

Maintain a regulatory calendar covering application dates, transition periods, labelling dates, reporting duties and phase-out deadlines.

11. Build an audit-ready evidence pack

Link each product to its applicable restrictions, supplier evidence, SDS, test reports, exemption decisions and approval records.

12. Review compliance continuously

Repeat the assessment when Annex XVII is amended, when products change, when suppliers change, when new markets are entered or when existing evidence expires.

Managing REACH Annex XVII manually with spreadsheets, emails and scattered supplier documents can quickly become unmanageable. Companies need to know which restrictions apply, which products are affected, which suppliers need to respond, which documents are missing, which tests are required and whether evidence is audit-ready.

ComplyMarket helps companies turn Annex XVII compliance into a structured, traceable and scalable process.

Automated restriction screening

ComplyMarket can help teams map products, materials, components and substances against relevant REACH Annex XVII restrictions, including substance groups, concentration limits, product scope, deadlines and exemptions.

Instead of manually checking each product against each update, compliance teams can identify affected products, materials and suppliers faster.

Supplier declaration management

Annex XVII compliance depends heavily on supplier data. ComplyMarket helps companies collect, organise and review supplier declarations in a controlled workflow.

This helps reduce reliance on vague supplier statements and supports more specific declarations linked to substances, entries, materials and thresholds.

Centralised evidence management

ComplyMarket enables teams to store supplier declarations, SDS, certificates, test reports, exemption decisions, approvals and supporting documents in one place.

This creates a single source of truth for compliance evidence instead of relying on email folders, local drives or disconnected spreadsheets.

BOM-linked traceability

For complex products, evidence must be linked to the correct component, material, supplier and SKU. ComplyMarket supports structured traceability so teams can connect Annex XVII requirements to product-level and material-level evidence.

This is especially valuable for electronics, automotive, industrial articles, consumer goods and products with multi-tier supply chains.

Testing governance

ComplyMarket can help teams manage risk-based testing decisions by identifying high-risk materials, linking test reports to products or components, and triggering reassessment when suppliers, materials or formulations change.

Regulatory change impact assessment

When Annex XVII changes, companies need to understand which products, materials and suppliers are affected. ComplyMarket helps teams assess regulatory change impact faster and prioritise actions before deadlines.

Audit-ready reporting

ComplyMarket helps product compliance teams prepare structured evidence packs showing:

• Which Annex XVII entries apply.
• Which products and materials were assessed.
• Which suppliers provided evidence.
• Which test reports support compliance.
• Which exemptions or derogations were used.
• Who reviewed and approved the compliance decision.

This makes REACH Annex XVII compliance easier to prove during customer audits, internal reviews, due diligence checks and authority inspections.

Cross-regulation compliance support

Annex XVII is only one part of product compliance. Many companies also need to manage REACH SVHC, RoHS, POPs, SCIP, PFAS, packaging, batteries, ESG requirements and Digital Product Passport expectations.

ComplyMarket helps companies manage these obligations in a more connected way, supporting product compliance, material compliance, supplier compliance and documentation workflows in one platform.

Is REACH Annex XVII the same as the REACH SVHC Candidate List?

No. The REACH SVHC Candidate List and Annex XVII are different obligations. The Candidate List mainly triggers communication and notification duties, while Annex XVII imposes restrictions or bans on the manufacture, placing on the market or use of certain substances, mixtures or articles.

Does REACH Annex XVII apply to finished articles?

Yes. Many Annex XVII restrictions apply to articles, including consumer products, textiles, leather goods, plastic articles, toys, jewellery, electronics, automotive components, coatings and other finished goods.

Is a supplier declaration enough for Annex XVII compliance?

Sometimes, but not always. A supplier declaration is stronger when it references the exact Annex XVII entry, substance, threshold, material and product scope. High-risk materials may also require SDS review, formulation data or laboratory testing.

How often should companies review REACH Annex XVII compliance?

Companies should review Annex XVII compliance whenever the regulation is updated, when suppliers change, when materials or formulations change, when new products are launched, when product claims change or when evidence expires.

What is the best way to prepare for customer audits or authority inspections?

Create an evidence pack that links each product to the applicable Annex XVII restrictions, supplier declarations, SDS, test reports, exemption decisions, approval records and change-control history.