Use this worksheet to connect REACH registration, safe management and downstream communication when reviewing EcoVadis evidence. ENV391 is the question identifier supplied for this working scenario, not a confirmed universal question. Check the actual questionnaire, option guidance and analyst comments before deciding which evidence is needed.
Information checked: October 28, 2026. Filenames below are suggested examples, not attachments obtained, reviewed or accepted by EcoVadis.
1. Core review logic
A “REACH certificate” alone is insufficient, and the OR route is not mandatory for every company. Eligible manufacturers outside the EEA may appoint an EEA-established Only Representative to undertake relevant importer obligations; importers may also register. Identify the actual supply-chain role first. ECHA: Only Representative
Connect substance/product identification → registration/exemption and coverage → SOP/risk controls → SDS updates → delivery/follow-up. Registration is not ECHA endorsement of safety throughout the supply chain and does not replace restriction, authorization or communication duties. Internal recommendations are not universal EcoVadis mandatory attachments.
2. Review and evidence matrix
Select conforms, supplement or not applicable (NA), recording reasons for NA. Item 1 accepts the appropriate registration, OR coverage or exemption evidence according to role, rather than requiring everyone to hold an OR certificate.
| Review area | Checks | Suggested evidence/filename | Status | Notes |
|---|---|---|---|---|
| 1. Registration/OR coverage | Match substance name, CAS/EC, registration number, registrant, OR appointment and covered importers; confirm tonnage, supply period, applicable uses or exemption basis. | ENV_EVD_REACH_OR_ENV391.pdf; registration correspondence, OR appointment/coverage letters and lists. | □ Conforms □ Supplement □ NA | Check current status/version, not merely an unexpired paper certificate. |
| 2. Safety SOP/work instructions | Describe receiving-to-customer identification checks, SDS review, training, handling/exposure controls, incidents and updates, with responsibilities and records. | ENV-SOP-REACH-01.pdf; training, inspection and revision records. | □ Conforms □ Supplement □ NA | Demonstrate implementation, version control and update triggers, not just a newly written SOP. |
| 3. SDS register | Record update date, product, supplier/issuer, version and delivery record; optionally add substance ID, market, owner and obsolete-version status. | SDS_Register.xlsx; version comparison and change tracking. | □ Conforms □ Supplement □ NA | These five fields are internal recommendations, not a universally prescribed legal register. Link SDS and delivery evidence. |
| 4. Representative SDS | Use the actual product's complete 16-section SDS for its market. EU 15.1: applicable legislation/Annex XVII/XIV; 15.2: whether the supplier performed a chemical safety assessment (CSA). Registration numbers belong in section 1 or 3 as applicable. | SDS_16Sections_REACH_Section15.pdf; classification basis, supplier data and applicable exposure scenarios. | □ Conforms □ Supplement □ NA | No universal “15.3 CSR.” Explain unknown/inapplicable data properly; never invent tests. Check actual delivery separately. |
| 5. Sustainability report (optional) | Cite existing chemical-management commitments and implementation, preserving company, year, pages and assessed scope. | Sustainability_Report_Chemicals_Excerpt.pdf. | □ Conforms □ Supplement □ NA | Include when relevant; public commitments alone do not prove implementation. |
| 6. Customer communication | Link SDS version, recipient, date, product and actual attachment to email, portal access or receipt records; separately check SVHC applicability. | ENV-TPL-SVHC-01_CustomerNotice.docx; actual messages/delivery logs. | □ Conforms □ Supplement □ NA | Blank templates do not prove notification; shipment receipts must identify the SDS/information version delivered. |
3. Common REACH/SDS distinctions
Registration status versus document expiry
REACH registration is not an ISO-style certificate renewed at fixed intervals. Verify continuing applicability, covered supply, OR appointment and dossier updates. Separately check service periods in private OR letters/contracts. ECHA requires registration information to remain current. Dossier updates
EU SDS section 15 has 15.1 and 15.2
Under REACH Annex II as amended by Regulation (EU) 2020/878, 15.1 covers substance/mixture safety, health and environmental legislation; 15.2 covers chemical safety assessment. Do not assign international regulations to 15.2 and create 15.3 for CSR. Other markets follow their applicable formats. Distinguish CSA (assessment) from CSR (report). EU SDS requirements
Check Annex XVII restrictions, Annex XIV authorization and other applicable law in 15.1, considering substance, use and exemptions. Merely naming lists does not prove compliance. Hazard, toxicology and ecology information needs reliable sources and necessary explanations; companies do not have to generate their own experimental result for every field.
Article 33 is not one procedure for all chemicals
Article 33 applies to articles containing Candidate List substances above 0.1% w/w. Supply recipients with sufficient safe-use information, at least the substance name. Consumer requests require a free response within 45 days. This differs from substance/mixture SDS supply and notification to ECHA. Supply-chain communication
For product-line examples such as GLOBALPRENE™ SBS, first determine legal product type, composition and market. A trade name does not establish registration, SVHC or SDS compliance; this article has not verified that brand's actual data.
4. Conclusion and supplementary-action record
“Conforms” means internally prepared against the current review criteria, not guaranteed EcoVadis credit, score or regulatory approval. Follow platform submission rules and available supplementation windows.
Question/questionnaire version: ENV391 (verify actual question) / ___
Assessed entity/product/supply-chain role: ___
Review conclusion:
[ ] Internally conforms: matched to current question; submit via platform process
[ ] Supplement/revise: correct issues below and review again
[ ] Partly NA: legal/role-based reasons recorded
Gaps and required evidence:
1. Registration/OR coverage or exemption: ___
2. SOP/work instructions and implementation: ___
3. SDS register/version and sections 15.1/15.2: ___
4. Customer delivery/applicable SVHC information: ___
5. Sustainability report excerpt, if relevant: ___
Attachment versions/pages: ___
Owner/deadline/follow-up conclusion: ___
Connect registration, safe handling and communication through traceable real evidence rather than filenames or blank templates.