Which Chemical Laws apply in the Netherlands?

Published on 7 January 2026 · Last updated 28 October 2026

Two EU regulations form the core of chemical law in the Netherlands: REACH (Regulation (EC) No 1907/2006) on registration, information and restriction of chemicals, and CLP (Regulation (EC) No 1272/2008) on classification, labelling and packaging. Both apply directly; the Dutch Environmental Management Act designates who enforces them (Article 18.2b Wet milieubeheer).

This page is for manufacturers, importers, distributors and brand owners, inside and outside the EU, that place chemicals, mixtures or products containing chemicals on the Dutch market. It explains which obligations follow from REACH and CLP, what changes in the CLP labelling rules and when, who supervises in the Netherlands and when legal advice makes the difference. Dealing with a REACH or CLP question now? Contact our chemicals lawyers in the Netherlands.

Which chemical laws apply to products sold in the Netherlands?

REACH and CLP apply to substances, mixtures and, for certain duties, articles. On top of that, Dutch law adds a general duty of care for anyone who professionally handles substances, and environmental and planning rules govern how chemicals are stored at a site (Article 9.2.1.2 Wet milieubeheer).

Instrument	What it covers	Who it mainly concerns
REACH	Registration of substances from 1 tonne per year, safety data sheets, substances of very high concern, authorisation and restrictions	Manufacturers, importers, downstream users, suppliers of articles
CLP	Hazard classification, labels and packaging of hazardous substances and mixtures	Manufacturers, importers, downstream users, distributors
Wet milieubeheer, Title 9.2	Duty of care, information duties and national rules for substances; enforcement of REACH and CLP	Anyone who professionally manufactures, imports, uses or supplies substances
Environment and Planning Act (Omgevingswet)	Rules for activities at a site, including storage of hazardous substances	Operators of sites and storage facilities

Sector rules come on top for specific products, such as cosmetics, biocides, plant protection products, toys and food contact materials. They are not covered here; ask us which sector rules apply to your product.

What does REACH require from manufacturers and importers?

No data, no market: substances on their own, in mixtures or in articles may not be manufactured or placed on the EU market unless they have been registered where required (Article 5 REACH). Each manufacturer or importer of a substance in quantities of one tonne or more per year must register it with ECHA (Article 6(1)).

Substances in articles: producers and importers of articles must register substances intended to be released from the article above one tonne per year, and notify substances of very high concern above one tonne and 0.1% weight by weight (Article 7(1) and (2)).
Safety data sheets: the supplier of a substance or mixture classified as hazardous under CLP, or of a substance that is PBT, vPvB or on the candidate list of substances of very high concern, provides the recipient with a safety data sheet compiled in accordance with Annex II (Article 31(1)).
Information in the supply chain: a supplier of an article containing a substance of very high concern above 0.1% must give the recipient enough information for safe use, and must answer a consumer’s request free of charge within 45 days (Article 33(1) and (2)).
Authorisation: substances in Annex XIV may only be placed on the market or used for an authorised or exempted use (Article 56(1)).
Restrictions: substances, mixtures and articles covered by a restriction in Annex XVII may only be manufactured, placed on the market or used under the conditions of that restriction (Article 67(1)).

How registration works in practice, including joint submissions and fees, is explained on our page on the registration requirement under REACH.

How can a company outside the EU comply with REACH?

By appointing an only representative. A manufacturer established outside the EU may, by agreement, appoint a person established in the EU to fulfil the importer’s registration obligations as its only representative (Article 8(1) REACH).

The only representative must also comply with all other importer obligations and keep information on quantities imported and customers supplied (Article 8(2)). The non-EU manufacturer informs the importers in the same supply chain, which are then treated as downstream users (Article 8(3)). Without an only representative, each EU importer registers separately. Which model works best depends on your distribution structure, and the agreement with the only representative determines who carries which cost and liability.

What does CLP require, and what changes in 2026 to 2028?

Manufacturers, importers and downstream users must classify substances and mixtures before placing them on the market, and suppliers must label and package hazardous substances and mixtures in accordance with CLP (Article 4(1) and (4) CLP). Distributors may rely on the classification made by an earlier actor (Article 4(5)).

CLP was substantially amended by Regulation (EU) 2024/2865, which entered into force in December 2024. A first set of new rules applies from 1 July 2026 and a second from 1 January 2027. Regulation (EU) 2025/2439 postponed the new rules on label formatting, relabelling, advertising and distance sales to 1 January 2028 (Article 2(2), (3) and (3a) of Regulation (EU) 2024/2865, as amended).

Part of the 2024 CLP amendment	Applies from	Source
First set of amendments (Article 2(2))	1 July 2026	Regulation (EU) 2024/2865, as amended by 2025/2439
Second set of amendments, including Annex IV (Article 2(3))	1 January 2027	Idem
Label formatting, relabelling, advertising and distance sales (Article 2(3a))	1 January 2028	Regulation (EU) 2025/2439, Article 1(c)

The Commission has also proposed further simplification of the CLP labelling rules (COM(2025) 531). That proposal is referred to in Regulation (EU) 2025/2439 but is not adopted law; check its status before you redesign labels for 2028.

Who enforces REACH and CLP in the Netherlands?

The Minister of Infrastructure and Water Management is responsible for administrative enforcement of REACH and CLP, and officials of the Human Environment and Transport Inspectorate (ILT) are designated to supervise compliance with REACH, CLP and the Wet milieubeheer (Article 18.2b(1) Wet milieubeheer; Article 1 Besluit aanwijzing toezichthouders fysieke leefomgeving). Other ministers enforce REACH and CLP in their own fields, such as workplace safety and consumer health (Article 18.2b(2)).

Depending on whether the issue concerns placing on the market, workers or consumer products, more than one inspectorate can therefore be involved. REACH requires Member States to set effective, proportionate and dissuasive penalties (Article 126 REACH). In the Netherlands, violations of the duty of care and of certain other rules on substances in Title 9.2 of the Wet milieubeheer are economic offences (Article 1a Economic Offences Act), and authorities can impose orders under administrative enforcement or subject to a penalty payment.

Has an inspector asked for your registration numbers, safety data sheets or SVHC information? Have a Dutch lawyer review your response before you send it; the documents you supply set the scope of the case.

How are chemicals storage rules regulated in the Netherlands?

Storage of hazardous substances at a site is not governed by REACH or CLP but by Dutch environmental and planning law under the Environment and Planning Act (Omgevingswet). Which rules apply depends on the activity, the substances and the quantities stored.

This page does not set out the technical storage requirements; if you operate or plan a storage facility in the Netherlands, ask us to check the rules and permits for your site.

Practical example: a US coatings manufacturer exporting to the Netherlands

Suppose a US manufacturer of industrial coatings ships around 20 tonnes per year of a coating to a Dutch distributor. The coating is a mixture that contains a substance imported in more than one tonne per year and is classified as hazardous under CLP.

Either the Dutch distributor registers the substance as importer, or the US manufacturer appoints an only representative in the EU (Articles 6 and 8 REACH). The labels and packaging must meet CLP before the product is placed on the market, and since 1 July 2026 the label must identify a supplier established in the EU, such as the Dutch distributor (Article 4(4) and (11) CLP). The Dutch customers must receive a safety data sheet (Article 31 REACH). The distribution agreement records who registers, who maintains the safety data sheets in Dutch and who responds to the ILT.

When do you need a Dutch lawyer for chemical regulation?

When you must choose between importer registration and an only representative, when a Dutch customer or distributor passes REACH or CLP duties on to you by contract, when an inspector requests documents or announces a measure, and when a restriction or authorisation decision affects your product.

MAAK Advocaten in Amsterdam advises manufacturers, importers and distributors on REACH and CLP compliance in the supply chain, drafts only-representative and distribution agreements, and assists in contacts with the ILT and other Dutch authorities, including objections (bezwaar) and appeals. See our chemicals lawyers page, our product regulation attorney page and the overview of product compliance in the Netherlands.

Frequently asked questions about chemical laws in the Netherlands

Do I need to register a chemical under REACH to sell it in the Netherlands?

Yes, if you manufacture or import the substance into the EU in quantities of one tonne or more per year (Article 6(1) REACH). Without a required registration, the substance may not be placed on the market (Article 5).

Can a non-EU manufacturer register under REACH itself?

Not directly. It can appoint an only representative established in the EU to fulfil the importer’s obligations (Article 8 REACH); otherwise each EU importer registers.

When do the new CLP label formatting rules apply?

From 1 January 2028. Regulation (EU) 2025/2439 postponed the rules on label formatting, relabelling, advertising and distance sales from Regulation (EU) 2024/2865 to that date.

Who enforces REACH in the Netherlands?

The Minister of Infrastructure and Water Management, with the ILT as designated supervisor, and other ministers in their own fields such as workplace safety and consumer health (Article 18.2b Wet milieubeheer; Article 1 Besluit aanwijzing toezichthouders fysieke leefomgeving).

What must I tell customers about SVHCs in my products?

If an article contains a substance of very high concern above 0.1% weight by weight, you must give business customers enough information for safe use, and consumers on request within 45 days (Article 33 REACH).

Primary sources

Dutch statutes are only officially available in Dutch, on wetten.overheid.nl. Judgments can be found on rechtspraak.nl by their ECLI number. Legal position checked on 28 October 2026.