REACH is the EU regulation governing the Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force in 2007 and places responsibility on industry to manage the risks from chemicals and to provide safety information on the substances they place on the market. It applies to all chemical substances on their own or in preparations as well as in articles, and impacts almost every company doing business in or exporting to the EU.
For battery engineers, REACH matters less as a single compliance checkbox and more as an ongoing constraint on materials selection: cell chemistry, electrolyte formulation, and pack materials all draw on substances that REACH tracks, restricts, or may restrict in future.
How REACH works
Manufacturers and importers are required to gather information on the properties of their chemical substances and register that information in a central database held by the European Chemicals Agency (ECHA), which coordinates evaluation of the submitted information and runs a public database of hazard information. Three mechanisms matter most for battery applications:
- Substances of Very High Concern (SVHC). Substances presenting high risk to human health or the environment are published on the Candidate List, updated twice a year. If an article contains an SVHC above 0.1% by weight, suppliers must inform their supply chain of it and how to use it safely, and must respond to consumer requests for the same information within 45 days, free of charge. If the SVHC content exceeds 0.1% and the total quantity placed on the market exceeds one tonne per year, ECHA must also be notified. The Candidate List is maintained directly by ECHA and updated roughly twice yearly (253 entries as of the most recent update), so it is worth checking current cell and pack materials against it periodically rather than relying on a one-time review.
- Authorisation (Annex XIV). A substance on the Annex XIV authorisation list cannot be placed on the market or used after a given date unless a specific authorisation has been granted for that use. This process is designed to ensure SVHCs are progressively replaced by safer alternatives where technically and economically feasible.
- Restriction (Annex XVII). Annex XVII lists restrictions on the marketing and use of certain substances, mixtures, and articles across the EU market, which can apply even to substances that do not otherwise require registration. Restricted substances may be limited in use or banned outright if they pose an unacceptable risk.
Relevance to battery design and manufacturing
A finished battery is treated under REACH as an “article,” with any liquid electrolyte inside it generally treated as an integrated mixture within that article. Substances of interest for battery engineers tracked under this framework include:
- Cobalt compounds, used in NMC and NCA cathodes, several of which have been added to the SVHC Candidate List
- NMP (N-Methyl-2-Pyrrolidone), a common electrode processing solvent, subject to restriction under Annex XVII
- PFAS (per- and polyfluoroalkyl substances), used in some binders, separator coatings, and electrolyte additives, currently the subject of an active EU-wide restriction proposal with several long-chain perfluoroalkyl substances already identified as SVHCs on the Candidate List, and short-chain alternatives now under increasing regulatory scrutiny as replacements come into wider use
Relationship to the EU Battery Regulation
REACH predates and operates alongside the EU Battery Regulation ((EU) 2023/1542), rather than being replaced by it. The Batteries Regulation entered into force in August 2023, superseding the earlier Battery Directive (2006/66/EC), and establishes its own harmonised framework for the full battery life cycle. The Commission, assisted by ECHA, is separately required to prepare a report identifying Substances of Concern present in batteries or used in their manufacture, focusing on substances that may harm health or the environment, or that hamper recycling of secondary raw materials.
Note: the Battery Regulation’s supply-chain due diligence obligations (covering cobalt, lithium, nickel, and natural graphite) were originally due to apply from 18 August 2025. Regulation (EU) 2025/1561, adopted July 2025 as part of the EU’s “Omnibus IV” simplification package, postponed this to 18 August 2027, and pushed the Commission’s due diligence guidelines from February 2025 to 26 July 2026. This is a timing change only; it does not alter the substance restrictions or the battery passport timeline (still from 18 February 2027), which is what this page is primarily concerned with, but it is worth knowing the due diligence deadline referenced elsewhere on this site has moved.
This creates two adjacent but distinct restriction routes for the same substance: a new substance can be restricted either through the existing REACH Annex XVII process, or through the parallel mechanism written into Article 6 of the Batteries Regulation itself, and industry bodies have raised concerns about the two processes duplicating each other. For a battery programme, the practical implication is that a substance can become non-compliant either through a REACH restriction or through an addition to Annex I of the Battery Regulation, and both need independent monitoring rather than treating one as a subset of the other.
Practical implications for engineers
- Track the SVHC Candidate List (updated twice yearly by ECHA) against every material in the cell and pack bill of materials, not just the cell chemistry itself
- Treat electrolyte solvent and additive selection as a REACH-relevant decision, not purely an electrochemical one, given NMP and PFAS exposure
- Maintain supply chain documentation showing SVHC content by weight for every article-level component, since the 45-day consumer disclosure obligation applies regardless of company size
- Monitor both REACH restriction proposals and Battery Regulation Annex I amendments as separate but related compliance tracks
References
- Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). eur-lex.europa.eu/eli/reg/2006/1907/oj/eng
- European Commission, REACH Regulation. environment.ec.europa.eu/topics/chemicals/reach-regulation_en
- Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries. eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
- ECHA, Candidate List of substances of very high concern for Authorisation. echa.europa.eu/candidate-list-table
- Regulation (EU) 2025/1561 of the European Parliament and of the Council of 18 July 2025 amending Regulation (EU) 2023/1542 as regards obligations of economic operators concerning battery due diligence policies. eur-lex.europa.eu/eli/reg/2025/1561/oj/eng
See also: EN / EU — European