Guide

REACH for Agrochemicals: Where 1907/2006 Meets 1107/2009

Regulation (EC) 1907/2006 (REACH) and Regulation (EC) 1107/2009 (Plant Protection Products) together govern agrochemicals on the EU market. Active substances used in plant protection products are not separately registered under REACH (Article 15 exemption) but co-formulants, adjuvants, intermediates and non-PPP uses of the same chemistry are. The Candidate List of Substances of Very High Concern (SVHC), the Authorisation List (Annex XIV), and the Restrictions List (Annex XVII) reach into agrochemical formulations through the co-formulant route, and the 2023 PFAS proposal and ongoing endocrine disruptor criteria revisions are reshaping what counts as acceptable formulation chemistry. This guide walks the boundary, the supply-chain documentation expected, and a practical path to a defensible REACH file for an agrochemicals manufacturer.

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The Article 15 exemption and where it stops

Article 15(1) of REACH exempts active substances and co-formulants used exclusively in plant protection products in the meaning of Regulation 1107/2009 from REACH Title II registration, on the basis that 1107/2009 imposes an equivalent or stricter evaluation. The exemption is use-based, not substance-based: the same chemistry sold for a non-PPP use (industrial cleaning, biocide, intermediate) carries a full REACH registration duty. Companies relying on the exemption must be able to demonstrate the exclusivity of the PPP use throughout their supply chain.

SVHC, Authorisation List and SCIP

Article 33 obliges suppliers of articles containing an SVHC above 0.1 % w/w to communicate sufficient information to allow safe use, and to notify ECHA via the SCIP database. The Candidate List is updated twice a year; in 2024–2026 several agrochemical-relevant substances (specific azole metabolites, certain surfactants) have entered the list. A formulation containing a Candidate List substance triggers the Article 33 obligation even where the active itself is exempt.

Annex XIV authorisation and Annex XVII restrictions

Substances on Annex XIV require an authorisation to be placed on the market or used after the sunset date; substances on Annex XVII are subject to use restrictions (e.g. the PFAS in textiles restriction, the lead in PVC restriction). Agrochemical formulators have been caught by Annex XVII restrictions on solvents and surfactants that were previously routine. The 2023 PFAS universal proposal, if adopted, will reach into adjuvant chemistry that has been in use for decades.

Safety data sheets and the extended SDS

Annex II of REACH (as revised by Commission Regulation 2020/878) sets the SDS content, including the extended SDS (eSDS) with Exposure Scenarios for substances registered above 10 t/y with a hazard classification. eSDS quality has been a multi-year ECHA enforcement priority; the most common findings are missing or generic exposure scenarios, inconsistencies between Section 8 and the exposure scenario, and outdated CLP classifications. Agrochemical SDSs face additional scrutiny under the 1107/2009 framework and Member State biocide/PPP authorities.

A 60-day readiness path

Days 1–10: substance inventory with use-mapping (PPP / biocide / industrial / intermediate) and REACH status. Days 11–25: Candidate List reconciliation across all formulations; close Article 33 gaps and verify SCIP notifications. Days 26–40: Annex XIV/XVII screen across formulations and supplier inputs; replace at-risk chemistry where possible. Days 41–55: SDS/eSDS refresh against Annex II 2020/878 and current CLP; close exposure scenario gaps. Days 56–60: enforcement-readiness rehearsal — pick three SVHCs and walk the full Article 33 communication trail to the customer.

Where this lives in V5 Ultimate

The clauses above aren't theoretical — every one maps to a shipped module and an industry profile. Jump to the parts of the product that turn this guide into evidence on a Monday morning.

Modules that do the work

Substance & formulation QMS

Use-status, REACH status and Candidate List on one spine.

SDS / eSDS generation

One controlled source — Sections, classification and exposure scenarios consistent by construction.

Supplier substance changes

Upstream changes opened as one controlled review.

Industries this hits hardest

Agricultural chemicals

Frequently asked

Do I need a REACH registration for an active substance used only in PPPs?

No — Article 15(1) exempts active substances used exclusively in plant protection products in the meaning of 1107/2009. The exemption ends as soon as the substance is placed on the market for any other use.

How does Brexit affect REACH for UK-EU agrochemical trade?

UK REACH operates in parallel to EU REACH with its own substance registrations, Candidate List and Annex XIV/XVII. An EU registrant has no automatic UK registration and vice versa; manufacturers trading both ways maintain parallel files.

Is the SCIP database obligation suspended for agrochemicals?

No — SCIP applies to articles containing SVHCs above 0.1 % w/w placed on the EU market, regardless of sector. Agrochemical product packaging (containers, closures, IBC components) is in scope where the packaging article contains a Candidate List substance.

When does the PFAS restriction take effect?

As of mid-2026 the universal PFAS restriction proposal is still under ECHA committee review, with sector-by-sector derogations under negotiation. Producers should already be inventorying PFAS-containing chemistry across active and inactive ingredients and modelling phase-out scenarios.

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