Preparing REACH or chemical-management evidence involves more than holding a registration document. Show that procedures operate, chemicals are controlled and safety information reaches the relevant downstream customers.
Information checked: October 28, 2026. This is a practical preparation framework, not an official fixed three-layer scoring formula. ENV391 is the identifier used in this series; verify the actual question and option guidance rather than treating it as a universal REACH question.
1. Three review layers: registration, management and communication
Layer 1: applicable registration, coverage or exemption
Identify whether the product is a substance, mixture or article and the company's manufacturer, importer or supplier role. Eligible non-EEA manufacturers may appoint an EEA-established Only Representative (OR); importers may also register. Not every company needs an OR, and safety management should not start only after an ECHA document arrives. ECHA: OR role
Do not treat REACH registration as an ISO-style certificate with a universal expiry date. Check status, substance/supply coverage, OR appointment and continuing updates; separately check private contract or coverage-letter periods. Dossier updates
Layer 2: traceable controls and SOPs
Explain substance matching, SDS review, training, exposure controls and change notifications across receiving, storage, handling, shipment and incidents. Connect procedures to actual records. Registration alone is not ECHA endorsement of risk control across the whole supply chain.
Layer 3: communication and delivery evidence
Link SDS or applicable safety information to product, version, customer, date and delivery record. SDS duties differ from REACH Article 33 information duties for SVHCs in articles. Assess product type and conditions separately rather than applying one SVHC notification procedure to every chemical. Supply-chain communication
2. Five evidence modules
1. Registration, OR coverage or exemption evidence
- Gather registration correspondence/numbers, OR appointment/coverage letters, covered importer lists or reasons registration is unnecessary.
- Match substance name, CAS/EC, legal entity, uses, supply period and applicable tonnage.
- Explain name/address differences through verifiable entity/site mappings. An unexpired paper alone does not establish applicable registration coverage.
2. Chemical-safety SOPs/work instructions
- Before receipt: identify substance/product, supplier, regulatory status and SDS version.
- During internal use: cover storage, handling, protection, training, abnormalities and incidents; retain work orders, inspections and training records.
- After shipment: assign SDS delivery, customer-response, update-notification and follow-up responsibilities.
- Make the whole process traceable, including owners, frequency and form identifiers in document control.
3. SDS register
Use Excel or a controlled system export. Recommended minimum fields are update date, product, company, version and delivery record. Add market, substance identifiers, owner and obsolete-version status as useful. These are management recommendations, not a universally prescribed legal form.
Link the register to actual SDS and delivery records. A screenshot without date, source or version does not fully demonstrate ongoing management.
4. Representative product SDS and section 15
Provide a complete 16-section SDS for the actual product and market, not an empty template. Choose products representative of assessed activities; add different risk/market cases where necessary.
- EU 15.1 — Regulatory information: assess applicable substance/mixture safety, health and environmental legislation, including Annex XVII restrictions and Annex XIV authorization. Explain applicability rather than merely naming lists.
- EU 15.2 — Chemical safety assessment (CSA): state whether the supplier has performed an assessment. A CSR records that assessment; the two terms are distinct.
- No universal 15.3 CSR field: other markets follow their formats and applicability. Registration numbers appear in SDS section 1 or 3 as required.
See Regulation (EU) 2020/878 amending REACH Annex II. Hazard/technical data require reliable sources. Explain unknown, inapplicable or untested information under the rules; never invent data for supplementation.
5. Customer communication and actual delivery
Alongside the SDS, retain sent email, system delivery logs, replies or receipts identifying attachments. Match product, version, customer and date.
Blank notification templates show preparation, not completed notification. Ordinary shipment receipts do not automatically prove SDS delivery. For applicable SVHC duties, retain applicability analysis and notification content, distinguishing customer communication from regulatory submissions.
3. Preparation and uploading advice
- Create an evidence chain, not an arbitrary merged file. Cross-reference registration/coverage → SOP → register → actual SDS → delivery proof, with question, filename, version, page and owner. Follow document limits/combining rules; do not concatenate unrelated material to avoid limits. Official combining rules
- Show genuine version control and improvement. Dates reflect actual publication/review. Retain register updates, training, notices and corrective-action records, rather than changing old documents' years.
- Match the question and assessed scope. Formal, recent, pre-existing and relevant evidence is persuasive. Five modules are an organizing method, not five mandatory uploads for every question or a score guarantee. Supporting-document guidance
Use the REACH/OR evidence review worksheet to record gaps, supplementation owners and follow-up conclusions.