CAS 1310-73-2 · REACH · European Union

Sodium hydroxide (caustic soda) under REACH

NaOH · 氢氧化钠

Status: Registered. Sodium hydroxide is fully registered under REACH at the highest tonnage band (>1,000,000 tonnes/year). Multiple lead registrants are listed (chlor-alkali producer consortia). The substance is on the published REACH registration database with a complete dossier.

NaOH is one of the most thoroughly registered substances in REACH and the lane is operationally clean: no Annex XIV restriction, no SVHC flag, no national exemptions to track. The compliance work is the OR or in-house registration on the EU side, plus the Member-State-language SDS pack. Most Chinese chlor-alkali exporters work through a Brussels or Hamburg-based Only Representative consultancy on a per-tonne or annual-fee basis.

Listing and threshold

Substance Sodium hydroxide (caustic soda) (CAS 1310-73-2), NaOH
Regime EU Regulation (EC) No 1907/2006: Registration, Evaluation, Authorisation and Restriction of Chemicals
Jurisdiction European Union (EU-27 plus EEA: Iceland, Liechtenstein, Norway)
Status Registered
Tonnage threshold Registration required for any importer or manufacturer placing >1 t/year on the EU market

Classifications under this regime

  • Skin Corr. 1A (causes severe skin burns and eye damage): H314
  • Met. Corr. 1 (corrosive to metals): H290
  • GHS pictograms: GHS05 (corrosion)
  • Signal word: Danger
  • NOT classified as Carcinogen, Mutagen, or Reproductive toxicant

Restrictions and conditions of use

  • Not on REACH Annex XIV (Authorisation list)
  • Not on REACH Annex XVII (Restriction list)
  • Not classified as SVHC (Substance of Very High Concern)
  • Subject to general CLP labelling requirements (Regulation 1272/2008)

Importer obligations

A non-EU producer cannot register directly under REACH. The EU importer of record must either hold a REACH registration in their own name or rely on an Only Representative (OR) appointment by the non-EU manufacturer. Pre-registration grandfathering is closed; new market entry requires a fresh registration submission with full dossier (data sharing through the SIEF / Substance Information Exchange Forum).

Required documents

  • REACH registration number on the EU side (registrant or OR-appointed)
  • Safety Data Sheet (SDS) compliant with REACH Annex II in the official language(s) of the destination Member State
  • Extended SDS (eSDS) with exposure scenarios for industrial / professional use
  • CLP-compliant labelling on packaging in destination-Member-State language

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

  • Importing without a registration or OR appointment is a customs-block at first arrival; fines can exceed EUR 100,000 per shipment in some Member States
  • OR arrangements expire and need renewal; verify the OR is current before shipping
  • SDS language requirements vary by destination Member State: Belgium requires Dutch plus French plus German; Spain requires Spanish; verify before invoicing
  • EU CBAM (Carbon Border Adjustment Mechanism) does NOT apply to caustic soda currently but is on the watch-list for 2030+ revision rounds

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for sodium hydroxide (caustic soda), see the CAS 1310-73-2 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the sodium hydroxide (caustic soda) cornerstone hub covers the full sourcing chain.

For the structure and history of REACH, see the REACH glossary entry.

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

Free download

Free PDF: the same MSDS verification template the Sourzi team uses to cross-reference factory documents against TSCA, REACH, AICIS, and CDR before booking.