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EU-wide REACH enforcement project

21 February 2023

Les Brèves de DS Avocats

Implementation starts in France

In November 2022, the European Chemical Agency (ECHA) announced that, over the 2023-2025 period, a REACH enforcement project would investigate how companies fulfil the registration, authorization and restriction obligations for products and chemicals they import from outside the EU. To this end, cooperation from national customs authorities in the Member States was sought.

On 07/02/2023, French Customs published a note on their website information of specific tariff provisions (DTP) related to compliance with REACH provisions and restrictions on the manufacture, placing on the market and use of certain dangerous substances and preparations and certain dangerous articles (listed in Annex XVII of the REACH Regulation).

As of 10/02/2023, operators importing in France are to mention on their customs declaration (DAU) either of the following DTP codes:

  • Y106: Compliance with REACH restrictions defined in column 2 of Annex XVII of Regulation (EC) No 1907/2006;
  • Y110: Exemption from REACH restrictions under Article 67(1) and (2) of Regulation (EC) No 1907/2006;
  • Y113: Product not subject to the provisions of Regulation (EC) No 1907/2006.

Several operators and trade federations have reported “customs blockages” following the implementation of these DTPs.

Since Tuesday 21 February, DTP Y113 now mentions Annex XVII of the REACH regulation and is worded as follows: “Product not subject to the provisions of Regulation (EC) No 1907/2006 (Annex XVII)”.

Therefore, operators importing substances subject to the provisions of the REACH Regulation but not falling under Annex XVII may therefore refer to DTP Y113.

The creation of these DTPs for dangerous chemicals might be supplemented by additional codes in the coming months, so as to encompass non-dangerous substances and then meet the objectives of the ECHA enforcement project above described.

Our team has a strong experience in advising international operators in managing their REACH compliance obligations We are at your disposal for any further information at:


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