What is Annex XVII in REACH Compliance

What Is REACH Annex XVII?

REACH Annex XVII is the Restricted Substances List under the European Union's REACH Regulation (EC No 1907/2006). It outlines specific chemicals that are either completely banned or restricted for use in consumer and industrial products on the EU market.

Each entry includes:

• The substance(s) covered
• The conditions or limits of restriction
• Specific exemptions or use cases

Some substances, like asbestos, are completely banned. Others, like phthalates or nickel, are subject to concentration thresholds or migration limits.

Why REACH Annex XVII Matters

• Non-compliance = market access loss.
• Applies to both raw materials and finished goods.
• Impacts global supply chains, not just EU-based production.

Manufacturers must be able to identify, screen, and substitute restricted substances before placing products on the EU market.

How Substances Are Added to REACH Annex XVII

1. Scientific Identification Collected data on toxicity, persistence, bioaccumulation, and long-term effects.

2. Risk Assessment Modeling exposure scenarios across consumer, worker, and environmental pathways.

3. Regulatory Proposal Restrictions proposed via dossier under Article 68, often following SVHC identification.

4. Public Consultation & Socio-Economic Analysis Weighs risk vs benefit and allows stakeholder engagement.

5. Commission Decision Finalized into law, published in the EU Official Journal, and added to Annex XVII.

See ECHA's Step-by-Step Restriction Process

Excellent catch — the “Types of Restrictions” (Concentration Limits, Total Content Limits, Outright Bans) were not explicitly labeled as such in the revised draft. While the content implicitly covers those concepts (via examples and the checklist), for clarity and SEO structure, it’s best to add a dedicated section with that exact heading.

Types of Restrictions in REACH Annex XVII

Annex XVII defines three primary types of restrictions, each with different regulatory implications:

• Concentration Limits

Limits the maximum concentration (%) of a substance allowed in mixtures or articles. Example: Benzene is banned in products if its concentration exceeds 0.1% w/w.

• Total Content Limits

Restricts the overall quantity of a substance in the entire product. Example: Cadmium content in plastics must not exceed 0.01% in total composition.

• Outright Bans

Certain substances are fully prohibited—no concentration is acceptable. Example: Asbestos is completely banned from any use in the EU.

These categories help regulators match the restriction approach to the hazard level, use case, and potential for exposure.

What are the Top Restricted REACH Annex XVII Substances

High-Risk Product Categories under REACH Regualtion

• Toys and childcare articles
• Electronics and electrical goods
• Apparel, textiles, and footwear
• Furniture and wood-based panels
• Automotive interiors and components

If you operate in these sectors, Annex XVII must be central to your compliance strategy.

5-Step Compliance Checklist for Annex XVII

1. Screen Your BOMs Use part-level data to identify matches with Annex XVII entries.

2. Collect Updated Supplier Declarations Request REACH compliance statements or Full Material Disclosures (FMDs).

3. Monitor Annex XVII Updates Sign up for ECHA newsletters and monitor CARACAL proceedings.

4. Substitute Where Required Prioritize safer alternatives when substances face new restrictions.

5. Centralize Documentation Prepare for audits with clear versioning and accessible evidence.

REACH Annex XVII Enforcement & Penalties

Each EU Member State designates national enforcement authorities. These bodies:

• Conduct inspections, audits, and sampling

• Require companies to present technical dossiers

• Impose penalties including:

  • Fines
  • Product recalls
  • Market bans

Compliance failure = business interruption + reputational risk

Real-World Adjustments: How to Stay Ahead of REACH Annex XVII

• Continuous Monitoring: Track proposed changes via ECHA and public consultations.
• Scenario Planning: Build substitution strategies before restrictions are finalized.
• Compliance Audits: Periodically validate REACH adherence across product lines.
• Digital Traceability: Use compliance platforms to store and update declarations.

Are You Tired of Manual REACH Screening?

One restricted substance can shut down your EU shipments.

Acquis makes REACH Annex XVII compliance effortless:

• Automate restricted substance detection in your BOM
• Centralize supplier declarations + FMD tracking
• Get notified of regulatory changes before they impact your SKUs

Reach out to our compliance expert for a quick compliance demo