The European commission has committed to improve the compliance for imported goods with REACH and CLP obligations with the aid of Customs authorities.
They evaluated the REACH requirements that could be integrated in customs procedures, and started with the integration of REACH Annex XIV – Authorisation list substances in TARIC (Integrated Tariff of the European customs Union) database. Companies that import an Annex XIV substance should either provide a valid authorisation, or demonstrate being subject to an exemption. The applicable TARIC codes are:
C073 – REACH Authorisation, according to Title VII of Regulation (EC) No 1907/2006
The importer has a valid Authorisation for their product use. The Authorisation number will need to be provided.
Y105 – Generic exemption from REACH authorisation (Art. 56 of Regulation (EC) No 1907/2006)
The product is exempt from Authorisation as defined by Article 56. This may be due to the Authorisation sunset date not being reached or a pending decision on authorisation if an application has been made 18 months before the sunset date. Furthermore, an exemption may apply to substances used in scientific research and development; authorised plant protection or biocide products; motor fuels; and cosmetics and food contact materials which are only classified as human health hazards.
Y109 – Specific exemption from REACH authorisation (exempted (categories of) use listed in Annex XIV of Regulation (EC) No 1907/2006)
The product is exempt from Authorisation based on a specific use. For example, the substance Dibutyl phthalate may use this code if specifically used for immediate packaging of medicinal products covered under Regulation (EC) No 726/2004, Directive 2001/82/EC, and/or Directive 2001/83/EC.
Y115 – Exemption from Authorization (Title VII) Article 2 point 5 and 8 of Regulation (EC) No 1907/2006
The product is exempt from Authorisation on grounds of Article 2 points 5 and 8.
Article 2 point 5 covers veterinary medicinal products, human medical products and foodstuffs, whilst point 8 refers to on-site isolated intermediates and transported isolated intermediates. If either point applies, Y115 may be claimed.
The second phase, Integration of REACH Annex XVII – Restriction list substances in TARIC, has been operational since February 2023. Companies that import products with commodity codes that are subject to REACH import control, need to provide one of the following TARIC codes in their customs declaration:
Y110 – Exemption from REACH restrictions by virtue of Article 67(1) and 67(2) of Regulation (EC) No 1907/2006
Substance is restricted but the use is exempt as per article 67 (1) (2):
- Scientific Research and Development (SR&D)
- Product and Process Orientated Research and Development (PPORD) – where specified in the restrictions entry
- Cosmetic products – where restrictions are imposed due to risks for human health
Y106 – Compliance with the REACH restrictions defined in Column 2 of Annex XVII of Regulation (EC) No 1907/2006
Substance is restricted and the Importer is in compliance
The code Y106 is used when the product contains a substance mentioned in column 1 of Annex XVII and the product is a product referred to in column 2, i.e. it is covered by the restriction. Make sure that the product fulfils the conditions for import mentioned in column 2.
Y113 – Product not subjected to the provisions of Regulation (EC) No 1907/2006 (Annex XVII).
The code Y113 is used when the product is not covered by the restrictions according to Annex XVII. The substance may still have other obligations under REACH.
In all cases, sufficient evidence to support the use of these TARIC codes must be recorded and ready to produce when requested to demonstrate that the conditions of the claimed code are met. To achieve compliance, we recommend that you start by checking with your customs agent, and review your processes for tracking substances of concern.
Need Support?
H2 can support you with the assessment of your inventory and setting up a process to comply, including bespoke software solutions.
For more information and help with complying, please get in touch.
Published November 18th, 2025
This article image was generated with the assistance of Artificial Intelligence.