CAS 7647-01-0 · REACH · European Union

Hydrochloric acid under REACH

HCl · 盐酸

Status: Registered. Hydrochloric acid is fully registered under REACH at the highest tonnage band (>1,000,000 tonnes/year). Multiple lead registrants are listed under the European chemical-industry consortium (chlor-alkali co-products, by-product from PVC and isocyanate manufacture). The substance carries a complete REACH dossier with a harmonised CLP entry under Annex VI Index No. 017-002-01-X for the gas and 017-002-00-2 for solutions.

HCl is REACH-clean from a status perspective but the Drug Precursors Category 2 listing layers the same Member-State-level registration requirements that apply to sulfuric acid. The China-EU HCl lane is small relative to caustic and sulfuric because Europe is structurally short on PVC capacity (HCl is a chlor-alkali by-product, in surplus at most plants, sold below merchant-acid pricing). Anhydrous gas (UN 1050) for semiconductor and pharmaceutical applications commands a premium and ships in dedicated tube-trailers; aqueous solution (UN 1789) for steel-pickling and water-treatment is bulk-tanker-tonnage commodity. Restriction 75 catches retail-grade product not industrial bulk.

Listing and threshold

Substance Hydrochloric acid (CAS 7647-01-0), HCl
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. 1B (causes severe skin burns and eye damage; 1B is less aggressive than the 1A applicable to sulfuric acid), H314
  • STOT SE 3 (specific target organ toxicity, single exposure, respiratory tract irritation), H335
  • Met. Corr. 1 (corrosive to metals), H290
  • Acute Tox. 3 (gas form, inhalation, anhydrous HCl only), H331
  • GHS pictograms: GHS05 (corrosion), GHS07 (exclamation mark, gas form adds GHS06)
  • Signal word: Danger
  • Harmonised classification under CLP Annex VI Index No. 017-002-01-X (gas) and 017-002-00-2 (solution)

Restrictions and conditions of use

  • NOT on REACH Annex XIV (Authorisation list)
  • NOT covered by REACH Annex XVII Restriction 75 (R75 is the tattoo-inks restriction under Reg (EU) 2020/2081, effective 4 January 2022, unrelated to acid retail). NOT under Reg (EU) 2019/1148 on Explosives Precursors (HCl is not on that schedule, unlike sulfuric, nitric, hydrogen peroxide). HCl public-sale restrictions are nationally implemented in some Member States (e.g. UK Offensive Weapons Act 2019 for >12.5% HCl as a "corrosive product"); verify destination Member State law before retail-grade supply
  • EU Regulation (EC) No 273/2004 on Drug Precursors Annex I Category 3: hydrochloric acid is scheduled alongside sulphuric acid, acetone, methyl ethyl ketone, ethyl ether, and toluene (verify against https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R0273-20230220). Category 2 contains acetic anhydride (2A), phenylacetic acid / anthranilic acid / piperidine / potassium permanganate / ANPP / NPP (2B); Category 1 covers ephedrine / pseudoephedrine / lysergic-acid / safrole and similar primary drug precursors. Wholesale and intra-community trade in Category 3 requires registration with national competent authority
  • NOT a regulated explosives precursor under Reg (EU) 2019/1148 (unlike sulfuric, which IS scheduled as Category 2 explosives precursor)
  • NOT classified as SVHC

Importer obligations

A non-EU producer cannot register directly under REACH. The EU importer of record must hold a registration in their own name or rely on an Only Representative (OR) appointment. The Drug Precursors registration with the destination Member State competent authority is the practitioner-facing layer (same workstream as for sulfuric acid). Anhydrous HCl gas (UN 1050) and aqueous HCl solution (UN 1789) are operationally different forms with different transport, storage, and SDS requirements; verify which form the customer requires before invoicing.

Required documents

  • REACH registration number on the EU side (registrant or OR-appointed)
  • Drug Precursors registration with destination Member State authority (HCl is Category 3 under Reg 273/2004, light-touch registration vs Category 2 acetic anhydride / KMnO4)
  • Safety Data Sheet (SDS) compliant with REACH Annex II in destination Member State language(s), with extended exposure scenarios
  • CLP-compliant labelling on packaging including the harmonised CLP Annex VI hazard statements
  • ADR-compliant transport documentation (UN 1050 anhydrous gas Class 2.3 + 8, or UN 1789 aqueous solution Class 8 PG II depending on form)

Common compliance traps

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

  • Anhydrous HCl gas (UN 1050) is far more restrictive than aqueous HCl solution (UN 1789) on transport and storage; first-time importers sometimes confuse the two forms
  • Drug Precursors Category 3 same as sulphuric acid and toluene; light-touch Member-State competent-authority registration (Category 2 substances like acetic anhydride and KMnO4 are tightly licensed instead)
  • Restriction 75 (>15% acid attack prevention rules) caught some chemical resellers off guard in 2021-2022
  • EU CBAM does NOT include HCl in 2026 Phase 1 scope
  • Some Member States (Germany, Netherlands) require additional national chemicals notification beyond Federal REACH
  • Steel-pickling-grade HCl spec varies by destination steel mill; verify chloride / iron / heavy-metal limits before invoicing

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for hydrochloric acid, see the CAS 7647-01-0 sourcing reference.

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.

Read next

Cross-jurisdiction profile and sourcing references

Referenced in

6 pages across the Sourzi moat

This term shows up in 4 regulatory pages, 1 topic clusters, 1 CAS profiles. Sample backlinks per content type below.

Regulatory (4)

Plus 1 more regulatory pages.

Topic cluster (1)

CAS (1)

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.