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REACH manages chemical risks through three closely linked mechanisms: the Candidate List, the Authorisation List and the Restriction List. Each sends a different regulatory signal and requires a different business response. This article focuses on one of these mechanisms and explains what it means in practice for companies operating in the EU market.

The Restriction List as a market rulebook

Readers familiar with the REACH Candidate List and the Authorisation List will immediately notice that the Restriction List operates on a different logic. Where the Candidate List serves as an early warning signal and Annex XIV introduces a permission-based system, Annex XVII establishes uniform market rules that apply to all actors without individual approvals.

Within REACH, the Restriction List (Annex XVII) plays a fundamentally different role from both the Candidate List and the Authorisation List. While those mechanisms focus on identifying substances of concern and, in some cases, allowing continued use under controlled conditions, the Restriction List sets binding market rules. Once a restriction applies, it defines what can and cannot be manufactured, placed on the market or used in the EU – for all actors, without exceptions granted on a company-by-company basis.

For companies, inclusion in the Restriction List is often where regulatory risk becomes concrete. Products may need to be reformulated, redesigned or withdrawn from the market. Supply chains may need to be restructured. Unlike authorisation, there is no application process to rely on. Compliance is binary: either the restriction is met, or the product cannot be sold or used.

What the Restriction List covers

The Restriction List is set out in Annex XVII of the REACH Regulation. It contains entries that restrict or prohibit:

• Substances on their own
• Substances in mixtures
• Substances in articles

Restrictions may take many forms. Some impose complete bans, others set concentration limits, specify permitted uses, or define conditions under which a substance may be used. Importantly, restrictions often apply to articles and imported products, making them highly relevant for downstream users, brand owners and importers.

A key point often misunderstood is that a substance does not need to be classified as an SVHC to be included in Annex XVII. Restrictions are used whenever an unacceptable risk is identified that requires EU-wide action.

How substances end up on the Restriction List

In contrast to the Candidate List and Authorisation List, where substances are first identified as SVHCs, restriction does not require SVHC status. This distinction is crucial for companies that may otherwise assume that absence from the Candidate List implies regulatory safety.

The path to Annex XVII usually begins with a concern identified by a Member State, ECHA, or the European Commission. A restriction proposal is prepared in the form of an Annex XV dossier, which must demonstrate that the risk posed by the substance is unacceptable and that a restriction is the most appropriate measure to address it.

This process is evidence-driven and highly dependent on assumptions about use patterns, exposure and alternatives. Once the dossier is submitted, it is subject to a public consultation. This consultation is a crucial – and often underestimated – opportunity for industry to provide data on actual uses, technical constraints, substitution timelines and socio-economic impacts.

ECHA’s Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) then evaluate the proposal. Their opinions feed into the final decision by the European Commission and Member States on whether and how the substance is added to the Restriction List.

Why the Restriction List often creates surprises

In practice, companies are frequently caught off guard by new or amended restrictions. This is partly because restriction processes often focus on consumer or environmental exposure rather than occupational risk, and partly because the most affected actors may sit far downstream in the value chain.

Restrictions may target specific uses or concentration thresholds that companies have relied on for years without regulatory issues. Once adopted, restrictions typically include fixed transition periods. After these expire, non-compliant products simply cannot be placed on the market.

Because Annex XVII applies uniformly, there is no fallback option comparable to authorisation. This makes early awareness and preparation critical.

Compliance obligations under the Restriction List

From a legal perspective, compliance with Annex XVII is straightforward in principle but demanding in practice. Companies must ensure that substances, mixtures and articles they manufacture, import or place on the market comply with all applicable restriction entries.

This requires:

• Accurate knowledge of substance composition, including impurities
• Reliable information from suppliers and downstream users
• Continuous monitoring of amendments to Annex XVII

Enforcement authorities increasingly focus on restrictions, particularly where consumer products or articles are concerned. Non-compliance can lead to product withdrawals, recalls and significant reputational damage.

Strategic implications beyond legal compliance

Unlike authorisation, where continued use may be possible through a granted application, restriction leaves no procedural fallback. Once the restriction is in force, the only options are compliance through redesign or substitution, or withdrawal from the affected market segment.

While the Restriction List sets legal limits, its impact goes beyond compliance. Restrictions can reshape markets by accelerating substitution, favouring alternative technologies and disadvantaging companies that are slow to adapt.

For many businesses, the key challenge is not whether they can technically comply, but how quickly and at what cost. Substitution may require reformulation, requalification, customer approvals or changes to manufacturing processes. These timelines rarely align neatly with regulatory transition periods unless preparation starts early.

What companies should do when a restriction is emerging

When a substance or use appears in ECHA’s restriction intentions or ongoing Annex XV dossiers, companies should act immediately. This includes mapping where and how the substance is used, assessing whether exposure assumptions reflect real-world conditions, and evaluating realistic substitution options and timelines.

Early, well-supported input during consultations can influence the scope of a restriction, transition periods and the treatment of specific uses. Late or generic responses rarely have an impact.

At REACHLaw, we support companies affected by restrictions through our Comply+Right framework, which combines three complementary services:

• Regulatory audit: Restriction applicability and compliance assessments
• Supply chain assessment: Mapping of articles, uses, and supplier data
• Stress test for strategic response: Support with technical and socio-economic input, plus planning for substitution and product transition

The objective is not only to achieve compliance, but to ensure that regulatory decisions are informed by realistic data and that companies are prepared well before restrictions take effect.

Final thought

Taken together with the Candidate List and the Authorisation List, the Restriction List completes the REACH regulatory framework. It is the stage at which regulatory signals translate into fixed market conditions.

The REACH Restriction List is where regulatory policy most directly translates into market rules. Companies that monitor developments, engage early and plan strategically can adapt in a controlled way. Those that wait often find that the rules have already been written – and that their room for manoeuvre is limited.

In an environment of increasing regulatory ambition, understanding Annex XVII is no longer a specialist task. It is a core element of product and supply chain strategy.

Unlike the Candidate List or the Authorisation List, inclusion in the Restriction List leaves no scope for individual permissions – making early awareness and preparation even more critical.