If a substance used or manufactured by your company appears on ECHA's Community Rolling Action Plan (CoRAP), it does not mean the substance is banned, restricted, or automatically non-compliant.

CoRAP identifies substances that Member States have prioritised for evaluation because there are concerns that their manufacture or use could pose risks to human health or the environment. The purpose of the evaluation is to clarify those concerns.

For companies, the important question is not simply “Is my substance on CoRAP?” but:

“Is this substance relevant to my business, what is being evaluated, and what should I do now?”

If you need the broader regulatory context first, see our REACH compliance guide.

What Is CoRAP Under REACH?

The Community Rolling Action Plan (CoRAP) is a three-year plan that prioritises substances for evaluation under REACH.

ECHA updates the plan annually in March. Substances may be prioritised based on factors including potential hazards, exposure potential, uses, and registered volumes.

The CoRAP database identifies the substance, the Member State responsible for the evaluation, the planned evaluation year, the initial concern and the current status.

The current CoRAP database should always be checked when assessing a substance because the plan and evaluation status can change.

Does Being on CoRAP Mean a Substance Is Banned?

No.

CoRAP inclusion is an indication that a substance has been prioritised for further evaluation. It is not itself a restriction, authorisation requirement, or SVHC designation.

The concern associated with a substance before evaluation is indicative rather than conclusive. The evaluation determines whether additional information or further regulatory action is warranted.

This distinction is important because companies should not automatically assume that a CoRAP substance must be removed from products.

Instead, they should assess whether the substance is relevant to their operations and monitor the evaluation.

What Happens After a Substance Enters CoRAP?

The process generally follows this path:

CoRAP inclusion
↓
Member State substance evaluation
↓
Additional information requested if necessary
↓
Evaluation conclusion
↓
Further regulatory action, if warranted

For substances scheduled for evaluation, the designated Member State evaluates the available information and can request additional information from registrants where necessary.

The outcome is not predetermined.

A substance may ultimately require no further regulatory action, while another evaluation could identify the need for additional information or further risk-management measures.

What Should a Company Do If a Relevant Substance Is on CoRAP?

1. Confirm that you actually use the substance

Start by checking whether the substance is present in:

• Raw materials
• Formulations
• Components
• Materials
• Finished products
• Manufacturing processes

Use the substance's CAS number, EC number or another reliable identifier rather than relying only on a similar chemical name.

If your screening process involves large BOMs and multiple components, see our guide to REACH SVHC screening tools.

2. Understand why it is being evaluated

Check the CoRAP entry for the initial grounds for concern.

These can include suspected hazardous properties, exposure considerations and other factors that led to the substance being prioritised.

This helps you understand what information may become important during the evaluation.

3. Review your registration and substance information

If your company is a registrant, review the information associated with the substance registration and identify any obvious data gaps.

If you are a downstream user, review the information available from your suppliers and determine whether your use is adequately understood.

4. Review supplier information

For substances sourced through your supply chain, check whether your supplier information is:

• Current
• Substance-specific
• Traceable to the relevant material/product
• Consistent with your own records

A general statement such as “REACH compliant” may not provide enough information to understand whether the substance is relevant to the CoRAP evaluation.

If the problem is the quality or reliability of supplier SVHC declarations, see our detailed guide on how to validate REACH SVHC supplier declarations.

5. Monitor the evaluation

Don't treat the original CoRAP entry as the final regulatory outcome.

Monitor the substance's evaluation status and any conclusions or decisions that follow.

This is particularly important because an evaluation can potentially lead to further REACH action.

What Does CoRAP Mean for Registrants and Downstream Users?

The impact depends on your role.

Registrants

Registrants may need to respond if the evaluating Member State determines that additional information is required to clarify the identified concern.

Downstream users

Downstream users should determine whether the substance is relevant to their uses and products, maintain appropriate supplier information and monitor the outcome of the evaluation.

Being a downstream user does not automatically mean that you will receive the same information request directed to a registrant.

Can CoRAP Lead to Further REACH Requirements?

It can, but the outcome is not predetermined.

The purpose of substance evaluation is to clarify potential risks. Depending on the findings, the evaluation may result in:

• No further regulatory action
• A request for additional information
• Further assessment
• Consideration of risk-management measures
• Potential SVHC identification or other REACH action where the relevant criteria are met

If an evaluation ultimately results in SVHC-related action, the REACH Candidate List updates become relevant.

If concerns progress toward restriction, see REACH's restriction roadmap.

If the substance subsequently becomes subject to authorisation, see REACH Annex XIV: hazardous substances and authorisation.

The important point is that CoRAP is an evaluation stage—not proof that one of these outcomes will occur.

CoRAP Monitoring Checklist

If you identify a substance relevant to your business on CoRAP:

• ☐ Confirm the substance identity
• ☐ Determine whether you use or manufacture it
• ☐ Check the planned evaluation year
• ☐ Identify the Member State conducting the evaluation
• ☐ Review the initial grounds for concern
• ☐ Review registration and supplier information
• ☐ Identify relevant data gaps
• ☐ Monitor the evaluation status
• ☐ Record your assessment and supporting evidence
• ☐ Reassess when new information becomes available

Stay Ahead of REACH Substance Changes

CoRAP monitoring can help companies identify potential regulatory developments before they result in further REACH action.

Regilient helps compliance teams connect regulatory requirements with products, materials, suppliers and compliance evidence so that regulatory changes can be assessed and managed systematically.

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