ECHA’s Enforcement Forum has defined the scope of new EU-wide enforcement projects to be carried out in the coming years. According to the decisions, inspections will focus on areas such as restricted hazardous substances in products, tattoo inks and permanent makeup, CLP implementation and the online sale of biocidal products.

Restricted Substances in Products to Be Inspected

Under REF-16, inspectors will check whether products and mixtures placed on the market comply with restrictions under EU chemicals legislation. The inspections will particularly examine whether:

  • restricted hazardous substances present in products are below the permitted limits,
  • products placed on the market comply with the legislation,
  • products offered through online sales channels meet the relevant requirements.

In cooperation with the European Commission and National authorities, it will also be assessed how findings obtained from online sales can support enforcement activities under the Digital Services Act.

. Inspections are planned for 2028, with the report expected in 2029.

Pilot Project on Tattoo Inks and Permanent Make-up Products

The Forum has also decided to launch a new pilot project on tattoo inks and permanent make-up products. Under this project, inspectors will check whether:

  • restricted substances are present above the permitted threshold values,
  • product labels comply with the legislation.

Inspections are planned to start in 2027, and the report will be published in 2028.

Rapid Enforcement Initiative on CLP Obligations

The Forum has also launched its first Rapid Enforcement Initiative (REI-1). Within the scope of this initiative:

  • it will be examined whether companies have updated their registration dossiers in line with harmonised classification and labelling decisions,
  • Member State authorities will carry out rapid and targeted follow-up activities for non-compliances identified by ECHA.

Online Sales of Biocidal Products Under Scrutiny

The Forum’s Biocidal Products Regulation Subgroup (BPRS) has announced that the next EU-wide biocidal products enforcement project (BEF-4) will focus on online sales and cross-border cooperation.

The inspections will particularly check whether online advertisements for biocidal products such as wood preservatives, rodenticides and insecticides comply with information requirements.

In addition, the inspections will check whether:

  • the products have a valid authorisation,
  • the products contain approved active substances,

Inspections are planned for 2028, with the report expected in 2029.

What Can You Do?

Although the inspections are planned to start in 2028, it would be beneficial for companies whose products may fall within this scope to begin preparations now.

In this context, companies should review their product portfolios and determine whether their products contain substances restricted under EU legislation. They are required to have comprehensive technical documentation to demonstrate compliance during inspections. Companies should also ensure that product descriptions, label information and legal warnings are complete. Attention should also be paid to compliance with product-type-specific requirements. These preparations will significantly reduce the risk of non-compliance during possible inspections.

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