EU REACH, UK REACH and Poison-Centre Notification for Adhesives

An adhesive mixture crossing into the EU triggers registration and notification duties that land on you, the importer, unless someone has taken deliberate steps to move them. Not on the forwarder, not on the customs broker, and not on the Chinese supplier — on the legal entity whose name is on the import. That is the single most expensive misunderstanding in this category, because it usually surfaces at the moment a distributor in Rotterdam or Hamburg asks for a UFI code you have not met before, three weeks after the pallet arrived.

None of this is exotic. It is three overlapping regimes with three different duty holders, and once you have drawn the map it stays drawn. Aosibo Adhesives lists the United Kingdom, Germany, France and the Netherlands among eight stated target markets — half the list sits inside the strictest chemical-registration regime this kind of product will meet. No registration, notification or safety data sheet was provided at its profile review, so none is claimed here. Everything below is what you would need to establish, in your own name or the supplier's, before a first order.

A mixture is not registered. Its substances are.

Start with the thing that trips up most first-time chemical importers. EU REACH does not register adhesives. It registers substances. Your drum of centring adhesive is a mixture of several substances, and the registration question is asked separately about each one, at the tonnage each one reaches.

The threshold is one tonne per year, calculated per substance, per legal entity, per calendar year. Two consequences follow that are worth internalising:

• A small first order probably does not require registration. If you import 400 kg of an adhesive and no single substance in it reaches a tonne in the year, registration is not triggered. That is a genuine relief and a genuine trap, because the exemption is annual and cumulative — the fourth reorder is what breaks it, and by then you have a customer expecting continuity.
• The tonnage is yours, not the supplier's. Two importers each bringing in 800 kg do not aggregate. This is why some buyers structure around it, and why anyone who does needs to be certain the entities are genuinely separate rather than a paper split, which is a question for counsel rather than for procurement.

Registration exemption is not exemption from everything else. Classification and labelling duties, safety data sheet duties and poison-centre notification duties do not switch off below a tonne. They are a different set of obligations with a different trigger, which is the second thing that catches people.

Three regimes, three duty holders

Confirm each row against current legislation with a regulatory adviser before you rely on it. The regimes are amended, and UK arrangements in particular have moved repeatedly since Brexit.

The only-representative mechanism, plainly

A manufacturer established outside the EU cannot register under EU REACH. What it can do is appoint an only representative — a natural or legal person established in the EU, with adequate practical experience in handling substances, who registers in respect of that manufacturer's exports. When that appointment exists and covers you, your imports are treated as supplies from an EU registrant, and you become a downstream user rather than an importer for registration purposes.

That is a real commercial benefit and it is not free. Someone pays the only representative's annual fee and the registration costs, including access to the data behind an existing registration. Suppliers who serve EU customers at volume often carry it and price it in; suppliers who have not shipped into the EU generally have not, and a first-time appointment takes time you have not budgeted.

Three questions decide whether an offered arrangement is worth anything to you:

1. Is there an appointment in place today, and who is the appointed entity? Ask for the name, the EU address, and the appointment letter. An intention is not an appointment.
2. Are you on the only representative's list of covered customers? The mechanism works through a maintained list of the importers and downstream users covered, with the tonnages supplied. If you are not on it, you are still the importer.
3. What tonnage band is registered? A registration covering 1–10 t/y does not cover you when your volume grows past it. Ask which band, and ask what happens if you exceed it.

If those answers are unavailable, you are the registrant when the threshold arrives. That is a workable position — it is just one you should choose deliberately rather than discover.

The safety data sheet sits under all three

Every regime above assumes a safety data sheet exists and is correct. For the EU market it must follow the format prescribed under REACH Annex II as currently amended, and it must be supplied in the official language of each member state where the product is placed on the market. A single English SDS does not serve Germany, France and the Netherlands.

Who authors it is negotiable and worth negotiating. A supplier-authored SDS in Chinese-inflected English, converted by machine translation, is a liability you inherit at the moment you put your name on the supply. The alternatives are to pay a consultant in your market to author it from disclosed composition, or to require an SDS authored to a named format revision as a condition of the order. Either way, the classification underlying it also drives your label, your transport documents and your poison-centre submission — get it wrong once and it is wrong in four places, including the UN number and packing group your forwarder books against.

Poison-centre notification and the UFI

This is the duty that most often gets missed, because it is newer than REACH and it is not covered by an only-representative appointment.

Under Annex VIII of CLP, mixtures classified as hazardous for health or physical effects and placed on the EU market require a notification carrying harmonised information: composition, toxicological information, product category, and packaging details. The submission generates or references a Unique Formula Identifier — a 16-character alphanumeric code that must appear on the label or the packaging of the product placed on the market.

The deadlines ran in stages, keyed to intended use: consumer and professional-use mixtures first, industrial-use mixtures later, with a transitional period for mixtures already notified under earlier national systems that has since ended. Confirm the current position with ECHA rather than working from a date in an article, including this one — but the practical reading for 2026 is that a hazardous adhesive mixture placed on the EU market now needs a notification and a UFI on the pack, whatever its use category.

Two operational details matter more than the legal text.

The duty is on whoever places it on the market. For an imported adhesive, that is you or your EU distributor, not the Chinese manufacturer. A REACH only representative does not discharge it. Buyers routinely assume one appointment covers both regimes; it does not.

Notification requires composition. Not a marketing description — the actual composition, at the concentration ranges the Annex prescribes. A Chinese supplier that treats its formulation as confidential has a real commercial reason to resist, and this is where a first EU order stalls. There are routes through it. Ask whether the supplier will disclose composition under a non-disclosure agreement to you, or directly to a regulatory consultant acting for you who reports only a conclusion. Ask whether any component is itself a purchased mixture with its own identifier that could be referenced rather than broken down. Then ask, in the same email, where the material is actually compounded and under whose licence — a repacker cannot disclose a composition it does not hold, and that answer changes the whole conversation. The same question sits at the centre of telling a blender from a compounder, which is the assessment underneath every answer on this page.

Great Britain is a separate exercise

Since Brexit, Great Britain operates UK REACH and GB CLP as separate regimes from the EU. An EU only representative does not cover a GB import. Northern Ireland's position differs again. GB poison-centre arrangements are not identical to the EU system and, at time of writing, do not use a UFI in the way EU CLP does — but this is precisely the area where confirming the current position with the HSE is worth an hour of somebody's time.

The UK transitional registration deadlines under UK REACH have been extended more than once and were still under review after the last extension. Do not plan a GB supply chain around a date you read anywhere except the HSE's own current guidance. If the UK is one of your destinations, the general shipping and entry mechanics in importing from China to the UK cover the freight side; the chemical registration side is a separate workstream that starts earlier.

A pre-order checklist for an EU or UK destination

Work through this before you place a first purchase order, not after the container books.

1. Fix the composition question first. Full composition under NDA, to you or to a consultant acting for you. Everything downstream depends on it.
2. Get the SDS for each grade, in the destination language, to the current REACH Annex II format. Check the revision date and the section numbering.
3. Get the CLP classification with hazard class, category, H-statements and signal word, and check it against the composition rather than accepting it. If a grade also carries a halogen-free claim, collect that test report in the same pass — it is a separate measurement, not part of the classification.
4. Establish the registration position. Ask whether an Article 8 only representative exists, who it is, whether you would be listed, and at what tonnage band. Get the appointment letter if the answer is yes.
5. Calculate your own annual tonnage per substance, not per product, for the volume you actually intend to buy in year one and year two.
6. Plan the poison-centre notification in your own name or your distributor's, and decide who generates the UFI and who prints it on the pack.
7. Handle GB separately if the UK is a destination. Confirm current UK REACH deadlines with the HSE and the GB poison-centre arrangement.
8. Confirm the compounding site and its licence, because the answers to steps 1 to 4 are only as reliable as the entity giving them.
9. Write the outcome into the contract — who holds which registration, who authors which document, who pays for a reclassification, and what happens if the formulation changes.

Step 9 is the one people skip. A formulation change that alters the classification invalidates the SDS, the label and the notification simultaneously. A written change-notification obligation costs nothing at contract stage and saves a recall conversation later.

Common questions

Can the Chinese supplier just register the product for us?

No, and not because of unwillingness. A non-EU manufacturer has no standing to register under EU REACH. The only route by which it can carry the registration burden is by appointing an EU-established only representative and funding that appointment. If a supplier says it is "REACH registered", that is the mechanism to ask about — the name of the appointed entity, the substances covered and the tonnage band. Ask for the appointment letter.

The first order is small. Does any of this still apply?

You may fall below the registration threshold. You do not fall below classification, labelling, safety data sheet or poison-centre duties, which apply to hazardous mixtures placed on the market regardless of tonnage. A 200 kg trial order still needs a compliant SDS, a CLP-compliant label in the right language, and a notification if the mixture is classified as hazardous.

What if the adhesive is not classified as hazardous?

Then the poison-centre notification duty does not apply to it, and the labelling requirements are lighter. That determination comes from the classification, which comes from the composition — which is why the composition question is step one rather than step five. Do not accept "non-hazardous" as an assertion; accept it as a conclusion supported by a classification you can see.

What to ask this supplier next

For any adhesive supplier whose stated markets include the EU or the UK, the first message should ask for six things at once:

• The full composition, under NDA, or a route to disclose it to a consultant acting for you.
• A safety data sheet per grade, in the destination language, to the current format revision.
• The CLP classification and the label artwork it produces.
• Whether an EU only-representative appointment exists, and if so the appointed entity's name and covered tonnage band.
• Whether the supplier has previously supplied any EU or UK customer, and who handled the registration on that occasion.
• Where the material is compounded and under whose licence.

Aosibo Adhesives is a useful example of why all six belong in one email rather than six. Its factory profile states target markets including the UK, Germany, France and the Netherlands, records that no destination-market registration documents were provided at review, and gives production lead time as 15 days company-stated. Fifteen days is faster than any of these compliance workstreams, which means the paperwork, not the factory, sets your real lead time on a first EU shipment. For the broader picture across destinations, the market-by-market import compliance checklist and the general China import compliance guide frame where chemicals differ from ordinary goods, and what an importer of record is and whether you need one covers the entity question that sits underneath every duty on this page.