In November 2025, the ECHA Forum, responsible for coordinating and strengthening the enforcement of EU chemicals legislation, defined the inspection programme for the 2026–2027 biennium.
The upcoming inspections will mark a shift in approach:
more integrated controls, supply chain–wide verification, and increased scrutiny of consistency between documentation and operational reality.
For chemical companies, importers, and formulators, the key concept will be: demonstrable compliance.
2026–2027 enforcement priorities: what authorities will check
Enforcement activities will focus on:
- REACH registrations, restrictions and authorisations
- Harmonised classification and labelling (CLH)
- Integrated controls across multiple regulations (REACH, CLP, BPR, POPs, etc.)
- Distance sales and online marketplaces
The approach will be cross-cutting: not just document verification, but concrete checks to ensure alignment between SDS, labels, PCN notifications, and the actual use of substances.
Why REACH 2026 inspections represent a concrete risk?
EU chemical safety legislation protects human health and the environment. However, the high number of non-compliance cases identified in recent years shows that the risk remains significant.
A notable example concerns online sales: the REF-8 project revealed that more than 3 out of 4 products sold online were non-compliant, and 78% did not comply with REACH restrictions.
The message is clear: authorities will intensify inspections where non-compliance is most widespread.
REF-14 and REF-15 Projects
To better understand what to expect, it is essential to review REF-14 and REF-15.
REF-14: Focus on CLP Classification and Labelling (2026) H3
REF-14 inspections are scheduled for 2026, with the final report expected in 2027.
The inspections will focus on the classification, labelling and packaging (CLP) of mixtures, particularly products containing sensitising, irritating, or toxic substances, such as air fresheners and e-cigarettes.
Authorities will verify:
- Correct classification and labelling
- Compliant packaging (e.g., child-resistant fastenings)
- Poison Centre Notification (PCN) compliance
What does this mean for companies?
For many organisations, the challenge will not be a single label, but the systematic and continuously updated management of hundreds of SDS and mixtures.
REF-15: Integration Between REACH and Occupational Safety (2027–2028) H3
REF-15 inspections are planned for 2027–2028.
The focus will be on the integration between REACH and Occupational Safety and Health (OSH), with particular attention to:
- Adequate information on safe use and handling in SDS
- Effective implementation of risk management measures in workplaces
- Compliance with restrictions for critical substances (e.g., diisocyanates, NMP, DMF)
- Proper use of substances subject to authorisation
At the same time, priority will be given to new regulatory provisions entering into application between 2026 and 2027, including:
- New CLP hazard classes
- New labelling requirements
- Rules on distance sales and advertising
This means that having a formally correct SDS will no longer be sufficient.
Authorities will assess whether the indicated risk management measures are actually implemented in practice.
How to Prepare for REACH and CLP 2026 inspections
Here is a practical checklist to avoid being unprepared.
1️⃣ Review Your Documentation
Ensure that SDS and labels are fully updated and compliant with REACH and CLP.
EPY X supports the drafting of compliant Safety Data Sheets and labels by:
- Highlighting restricted, authorised, PIC and POP substances in Section 15
- Automating UFI generation
- Generating PCN dossiers for hazardous mixtures
2️⃣ Check Products Placed on the Consumer Market
Under CLP, products sold to consumers must include:
- Child-resistant fastenings
- Tactile warnings of danger
- Mandatory precautionary statements (e.g., P101, P102)
It is also essential to verify that products not permitted for consumer use — such as those containing CMR substances above legal thresholds — are not placed on the market.
Errors in these areas are among the most frequently sanctioned non-compliances.
3️⃣ Invest in Training and Continuous Regulatory Monitoring
The regulatory landscape is constantly evolving, and staying informed is a core component of compliance.
For this reason, EPY Academy offers Dedicated training courses, webinars and in-depth regulatory updates curated by our internal Regulatory Team to support continuous regulatory alignment.
Chemical Compliance 2026: from regulatory obligation to competitive advantage
ECHA inspections in 2026–2027 should not be seen only as a sanction risk.
Companies investing in:
- Regulatory automation
- SDS management software
- Continuous REACH/CLP monitoring
- Technical training
can transform compliance into:
✔ Reduced legal risk
✔ Greater credibility with customers and distributors
✔ Stronger market reputation
✔ Operational efficiency
Is your company ready for the 2026 inspections?
Our automated SDS management software supports:
- REACH and CLP compliant drafting
- Continuous classification updates
- UFI and PCN dossier generation
- Monitoring of restricted and authorised substances
