CAS 7664-93-9 · REACH · European Union

Sulfuric acid under REACH

H2SO4 · 硫酸

Status: Registered. Sulfuric 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. The substance carries a complete REACH dossier with classification, exposure scenarios, and harmonised CLP entry.

Sulfuric acid is the dual-use compliance lane that catches new EU importers off guard: REACH itself is operationally clean (registered, no Annex XIV, no SVHC) but the Drug Precursors and Explosives Precursors regulations layer additional Member-State-level registrations on top. Battery-grade and electronic-grade sulfuric acid imports through dedicated OR consultancies is the normal-pattern lane; bulk sulfuric for fertiliser-makers (ammonium sulfate, single superphosphate) typically clears via the customer's in-house compliance team. Restriction 75 (>15% acid attack prevention) keeps retail-grade product out of general-public hands but does not affect industrial B2B trade.

Listing and threshold

Substance Sulfuric acid (CAS 7664-93-9), H2SO4
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
  • Carcinogen Cat. 1A (mists from strong inorganic acids, only when inhaled as mist), H350i
  • STOT RE 1 (specific target organ toxicity, repeated exposure, respiratory tract), H372
  • GHS pictograms: GHS05 (corrosion), GHS08 (health hazard)
  • Signal word: Danger
  • Harmonised classification under CLP Annex VI Index No. 016-020-00-8

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). The public-sale restriction on >15% sulfuric acid is governed by Reg (EU) 2019/1148 on Explosives Precursors directly, NOT through Annex XVII; verify against https://eur-lex.europa.eu/eli/reg/2019/1148
  • EU Regulation (EC) No 273/2004 on Drug Precursors: sulfuric acid is a scheduled drug precursor; verify the current Annex I Category assignment (Category 2 vs Category 3) at https://eur-lex.europa.eu/legal-content/en/LSU/?uri=CELEX:02004R0273-20230220 before relying on the prior dataset Category 2 attribution (search of EU drug-precursors framework returned acetic anhydride + KMnO4 as Cat 2A/2B examples and acetone + HCl as Cat 3 examples; sulfuric acid placement needs direct verification). Wholesale and intra-community trade requires registration with national competent authority
  • EU Regulation (EU) 2019/1148 on Explosives Precursors (effective 1 February 2021, repealed and replaced Reg (EU) 98/2013): concentrations >15% w/w are a "regulated explosives precursor" and may not be supplied to the general public; suspicious-transaction reporting and licence framework apply, scope details at https://eur-lex.europa.eu/eli/reg/2019/1148

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. For sulfuric acid specifically, the Drug Precursors registration with the destination Member State competent authority is a separate workstream beyond REACH itself, plus the Explosives Precursors notification system for higher concentrations. The substance carries a heavier compliance overhead than ordinary industrial chemicals due to the dual-use precursor framework.

Required documents

  • REACH registration number on the EU side (registrant or OR-appointed)
  • Drug Precursors registration with destination Member State authority (Category 2 sulfuric acid >15% w/w)
  • Explosives Precursors notification for concentrations >15% (per Regulation 2019/1148)
  • Safety Data Sheet (SDS) compliant with REACH Annex II, Member State language(s), with extended exposure scenarios
  • CLP-compliant labelling on packaging including the harmonised CLP Annex VI hazard statements

Common compliance traps

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

  • The Drug Precursors registration is per Member State competent authority and must be renewed; lapsed registrations trigger inter-Member-State trade blocks
  • Restriction 75 (>15% acid attack prevention rules) caught some chemical resellers off guard in 2021-2022, with auditors verifying packaging tamper-evident seals on retail-grade product
  • Sulfuric acid mists are CLP-classified Carc. 1A; SDS exposure scenarios must address mist generation in process design
  • EU CBAM (Carbon Border Adjustment Mechanism) does NOT include sulfuric acid in the 2026 Phase 1 scope but downstream products like ammonium sulfate fertiliser are in scope
  • Some Member States (Germany, Netherlands) require additional national-level chemicals notification beyond Federal REACH

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for sulfuric acid, see the CAS 7664-93-9 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the sulfuric acid 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.

Read next

Cross-jurisdiction profile and sourcing references

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