On April 16, 2020, the Nordic Council of Ministers published the results of a joint enforcement project focused on chemical compliance of products purchased online. Inspectors checked 361 products ordered online from 161 different companies for compliance with various pieces of EU chemicals legislation including REACH, Classification, Labelling, and Packaging Regulation (CLP), Restriction of Hazardous Substances Directive (RoHS), and regulations on biocides. The products included toys, electrical products, and cosmetic and hygienic products among others. Food packaging was not reported as being included within the sampling effort.

Across all of the products tested, 53% of products were found to be non-compliant with one or more of the considered pieces of legislation. A much higher rate of non-compliance was found for products purchased from companies outside of the EU (78%) than for companies within the EU (32%). Common violations were found for lead in the solders of electrical products, short chain chlorinated paraffins (SCCPs) in soft plastic, and boron migrating from slime toys. Substances on the EU’s candidate list of substances of very high concern (SVHCs) for authorization were also widely found to be present in the tested products, especially the phthalates diethylhexyl phthalate (DEHP; CAS 117-81-7) and dibutyl phthalate (DBP; CAS 84-74-2).

Products found to be non-compliant during the enforcement effort were addressed by the authorities. Companies in the EU were responsive in removing non-compliant products or changing incorrect labeling information, whereas some companies outside of the EU were not responsive and continue to sell non-compliant products. The survey notes that online marketplaces play a unique role in selling products on the EU market and that the original manufacturer of the products may not have designed their products to be compliant in the EU. Direct web shops from companies selling their products were found to be more compliant than online marketplaces.

The report clarifies that sampling was conducted based on products known to be of higher risk from previous enforcement experience and therefore not random. The project aimed to develop a methodology for inspecting and enforcing compliance of products sold online, and the report discusses some of the different tools and strategies that were tested.

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Chemical Watch (April 29, 2020). “Nordic controls find high non-compliance rate in online sales.”


Nordic Council of Ministers (April 16, 2020). “Nordic project on enforcement of internet trade.”