Product safety and chemical compliance pack

At a glance

Checked 7 November 2026. Only the Article 33 row is quoted from the legislation. Candidate List contents, POPs detail and the current product safety framework were not read and are listed in the unverified notes.

The Article 33 duty, in plain words

UK REACH Article 33, as shown on legislation.gov.uk (latest revised text, headed “U.K. Duty to communicate information on substances in articles”), says that a supplier of an article containing a substance on the Candidate List above 0.1% weight by weight must give the recipient the substance’s name at the least, and any other safe-use information it reasonably has. A consumer who asks is entitled to the same information, free of charge, within 45 days.

Two points matter for a designer. First, the threshold applies to the article, which for a bespoke piece is normally read as the finished item or its components, so the workshop needs a record of what is in each part. Second, the duty runs down the chain: a supplier who is not told by its own suppliers cannot tell you. The gov.uk review of Article 33 (published 29 June 2023) found most suppliers knew of the duty but that some were uncertain what hazardous substances were in their articles.

The Candidate List is kept by the Health and Safety Executive as a spreadsheet; its page showed “Updated 2026-03-09”. Reports on 2026 additions disagreed on the count, so we state none. Check the live list, and date your request to a list version.

Other regimes to name in a request

• Persistent organic pollutants (POPs). A GB regulation restricts certain persistent chemicals, some of which were used as flame retardants. We could not read the regulation this session, so we name no substance or limit. Ask for a statement that no restricted flame retardant is present in foam, fabric, backing or interliner, and ask which retardant is used if one is.
• General product safety. The General Product Safety Regulations 2005 (SI 2005/1803) set a general safety requirement for consumer products. We read only the contents page. Reports say the Product Regulation and Metrology Act 2025 is an enabling framework that will change this, but its detail and timing were not established. Ask your adviser which applies to a contract or domestic order.
• EU REACH and EU goods. Goods placed on the EU market (and in Northern Ireland) sit under a separate REACH list. See shipping bespoke furniture, UK to EU.
• Emissions. Formaldehyde and VOC limits for panels and finishes are on their own sheet: formaldehyde and VOC emissions.
• Fire retardants. A fire test says a piece passes; it does not say what chemical made it pass. See interliners and flame-retardant upholstery.

What a pack should contain

A useful pack is short and dated. It does not need to prove a negative for every chemical; it needs to show that the workshop knows what is in the piece and has asked its suppliers the right questions.

Do not accept a bare phrase such as “REACH compliant”: it names no regime, list version or date. Ask which regulation, which list and as of when.

What a supplier can say, and what you should not

A supplier can say which statements it has collected and the date of the list it checked against. It should not claim a product is “free of harmful chemicals”, and a specifier should not repeat such a claim to a client. Where a supplier cannot answer, record the gap in the pack rather than leaving it blank; a known gap is easier to manage than a silent one.

Keep the pack with the other project paperwork, as described in the handover and O&M pack, and add it to your tender sustainability documents where the client asks for it.

The Supplier provides before [order / delivery] a written statement, dated to a stated version of the UK REACH Candidate List, of whether any Candidate List substance is present above 0.1% weight by weight in the item or any component, naming the substance and giving the safe-use information required by UK REACH Article 33.

If the Candidate List changes in a way that affects the item before [handover], the Supplier notifies [the Specifier] in writing within [10] working days of becoming aware.

The Supplier states in writing which flame-retardant substances or treatments are used in foam, fabric, backing and interliners, and confirms that none is restricted under the UK persistent organic pollutants rules in force on the date of the statement.

Safety data sheets for [finishes and adhesives] are provided on request. Any change of material, finish, treatment or supplier after approval requires written notice and an updated statement before the item is made or shipped.

The Supplier keeps its supporting records for at least [5] years and provides them to [the Specifier] on request.

Standards and sources

• UK REACH, Article 33, as retained (legislation.gov.uk, latest revised): Read 7 Nov 2026.
• gov.uk: Review of Article 33 duties (UK REACH): Published 29 Jun 2023; read 7 Nov 2026.
• HSE: UK REACH Candidate List: Page updated 9 Mar 2026; spreadsheet not read.
• General Product Safety Regulations 2005 (SI 2005/1803): Contents read; current status not read.

Questions we are asked

What does UK REACH Article 33 require of a furniture supplier?

If an article contains a Candidate List substance above 0.1% weight by weight, the supplier must give recipients the substance name and any other safe-use information it reasonably has, and answer a consumer who asks, free, within 45 days.

Is a REACH compliance statement enough?

Not on its own. It names no regime, list version or date. Ask for a dated statement against a stated version of the UK Candidate List, and ask separately about flame retardants.

How many substances are on the Candidate List?

This sheet does not say. The HSE list is a spreadsheet that we did not read, and reports on 2026 additions disagreed. Check the live list.

Do the same rules apply to goods going to the EU?

No. The EU keeps its own REACH list and duties. Ask the EU buyer what it needs.

Does a fire test show a flame retardant is safe?

No. A test shows how the material burns. Ask separately which substance is used and whether it is restricted.

Is this legal advice?

No. Chemical and product rules change often, so confirm with your contract adviser or the relevant authority before you rely on anything here.