SVHC compliance for importers and exporters under EU REACH
What SVHC compliance means for traded goods
SVHC compliance means checking whether goods placed on the EU market contain substances of very high concern on the REACH Candidate List, assessing those substances against the 0.1% weight-by-weight threshold, and meeting the related communication, notification and recordkeeping duties. For importers and exporters, this is not only a laboratory question. The answer depends on article structure, supplier data, substance identity, concentration, market role and timing. ECHA has stated that adding a substance to the Candidate List can create immediate duties under REACH, particularly under Articles 7, 31 and 33. For context, ECHA announced on 4 February 2026 that the Candidate List contained 253 entries after two additional chemicals were added. (echa.europa.eu)
This guide focuses on finished goods, components and materials moving through international trade into the EU. It is written for purchasing, logistics, quality and compliance teams that need a workable control process, not a chemistry lesson. More trade compliance updates are available in our Compliance section.
Start with the legal trigger, not the product name
Under EU REACH, an SVHC is a substance identified as being of serious concern for human health or the environment and placed on the Candidate List for possible future authorisation control. For most import and export teams, the practical trigger is whether a Candidate List substance is present in an article above 0.1% weight by weight. ECHA guidance makes clear that articles such as clothing, flooring, furniture, jewellery, newspapers and plastic packaging can be within scope. Substances and mixtures may trigger different duties, including safety data sheet updates. (echa.europa.eu)
The company’s role in the supply chain matters. A non-EU manufacturer or exporter is normally not the direct REACH duty holder unless it has an EU legal presence or specific arrangements. The EU importer, distributor or supplier, however, needs reliable data from the overseas supply chain. In practice, EU buyers often require declarations, substance data and test evidence from non-EU exporters because the importer cannot meet its own obligations without them. ECHA’s information for non-EU companies notes that an EU-established importer of articles may have information and notification obligations where articles contain Candidate List substances. (echa.europa.eu)
The 0.1% threshold applies at article level
A frequent error is to calculate SVHC concentration only across the total finished product. For complex products, the 0.1% threshold is assessed at the level of each article that remains an article in the assembled product. The Publications Office of the European Union summarizes the 10 September 2015 Court of Justice ruling in case C-106/14 as clarifying that REACH Articles 7(2) and 33 apply to articles present in complex products as long as those articles retain their special shape, surface or design and have not become waste. (op.europa.eu)
This point is important for traded goods such as electronics, garments, machinery, toys, accessories and packaging. A finished item may contain hundreds of separate articles, including cables, coatings, plastic housings, fasteners, labels, rubber seals, textile panels and metal parts. If one small component contains a Candidate List substance above 0.1% by weight of that component, communication or notification duties may be triggered even when the concentration across the finished product is much lower.
Core SVHC duties for importers, suppliers and exporters
SVHC compliance is easier to manage when it is broken into decision points. The table below separates the obligations most often relevant to traded goods.
| Obligation | Main trigger | Who is usually affected | Practical evidence to keep |
|---|---|---|---|
| Supply chain communication under REACH Article 33 | Article contains a Candidate List substance above 0.1% w/w | Supplier of the article in the EU supply chain | Substance name, affected article, safe-use information, supplier declaration and supporting assessment |
| Consumer response duty | Consumer asks whether an article contains SVHCs above the threshold | Supplier of the article | Procedure showing response within 45 days, free of charge |
| Notification of substances in articles under REACH Article 7(2) | Candidate List substance above 0.1% w/w and total quantity above one tonne per producer or importer per year, unless an exemption applies | EU producers and EU importers of articles | Tonnage calculation, exposure or registration exemption review, IUCLID or REACH-IT submission records where applicable |
| SCIP notification | Article placed on the EU market contains an SVHC above 0.1% w/w | Companies supplying such articles on the EU market | Article identification, material or mixture category, Candidate List substance, concentration range and safe-use information |
| Safety data sheet updates | Candidate List substance supplied on its own or in a mixture where SDS rules apply | EU and EEA suppliers of substances or mixtures | Updated SDS and customer communication records |
ECHA states that Article 33 information must be provided to business recipients directly after a substance is included in the Candidate List where the article exceeds the 0.1% threshold. Consumer requests must be answered within 45 days free of charge. ECHA also states that producers and importers must notify ECHA under Article 7(2) when both the 0.1% concentration condition and the one-tonne-per-year condition are met, with notification no later than six months after inclusion of the substance in the Candidate List. (echa.europa.eu)
SCIP adds another reporting layer. ECHA describes SCIP as the database for information on Substances of Concern In articles as such or in complex objects under the Waste Framework Directive. Companies supplying articles on the EU market that contain Candidate List SVHCs above 0.1% w/w have had to submit information to ECHA from 5 January 2021. (echa.europa.eu)
A practical SVHC compliance workflow
A reliable workflow should follow the product, not just the invoice. For each product family, start with a bill of materials that identifies individual articles and materials. The file should be detailed enough to locate higher-risk components and answer a customer or regulator without rebuilding the assessment from the beginning.
- Map the article structure. Break complex goods into components that may remain articles in the final product. Do not rely only on the finished SKU weight.
- Collect supplier declarations. Ask suppliers to state whether Candidate List substances are present above 0.1% w/w at article level. Declarations should identify the Candidate List version or assessment date used.
- Request positive disclosure when relevant. If SVHCs are present, obtain the substance name, EC or CAS number if available, affected component, concentration range and safe-use information.
- Use targeted testing where supplier data is weak. Testing is most useful when focused on known risk materials or disputed declarations. A broad “SVHC-free” certificate without article-level coverage may not be enough.
- Evaluate EU duties. Determine whether Article 33 communication, Article 7(2) notification or SCIP submission is required.
- Control changes. Reassess when the Candidate List changes, when suppliers change materials, when production moves, or when the product design is updated.
This workflow is not a substitute for legal advice, but it gives trade teams a defensible way to turn regulatory duties into procurement and documentation steps.
Documents and data points to collect
Many SVHC failures occur because the importer has a declaration but not the underlying data needed to prove or act on it. A useful compliance file should show what was checked, when it was checked, who provided the data and which version of the Candidate List was used.
- Product name, model number, SKU and revision.
- Article or component breakdown, including replaceable parts and packaging where relevant.
- Supplier name, manufacturing site and declaration date.
- Candidate List version or assessment date.
- Substance identity for any positive finding, including name and identifiers where available.
- Concentration result or concentration range by article.
- Safe-use information provided to recipients.
- Test report scope, method, laboratory and sample description, where testing is used.
- SCIP reference or submission evidence, where applicable.
- Review date and trigger for next reassessment.
Declarations need to answer the legal question. A statement that a finished product is “REACH compliant” may help as a commercial assurance, but it does not show whether each article contains Candidate List substances above 0.1% w/w. When the answer is negative, the file should show the basis for that conclusion. When the answer is positive, the file should support communication, notification and customer response duties. See also: Customs.
Common risk areas in supply chains
SVHC risk is not evenly distributed across all goods. Trade teams should pay closer attention to materials and processes that commonly involve additives, plasticisers, flame retardants, stabilisers, pigments, coatings, adhesives, rubber compounds, textile treatments, metal finishing chemicals or specialty solvents. This does not mean every product using those materials is non-compliant. It means those areas deserve better supplier questions and, where necessary, targeted testing.
Packaging should not be overlooked. Plastic bags, labels, cable ties, inserts, coatings and printed materials may be treated as articles or parts of the supplied product depending on the supply situation. If packaging is placed on the EU market together with the product, importers should decide whether it must be included in the SVHC assessment and keep the reasoning in the file.
Outdated documentation is another common risk. A test report or supplier declaration may have been accurate when issued, but the Candidate List can change and materials can change. A practical control is to align annual supplier renewals with Candidate List checks and require suppliers to notify buyers before changing materials, formulations or production sites.
How to keep SVHC compliance current
The Candidate List is not static, so SVHC compliance should be managed as a living control. At minimum, importers should review affected product lines after official Candidate List updates, before launching a new EU-bound product, when a supplier changes materials, and when a customer requests updated REACH or SCIP evidence. The February 2026 ECHA update is a reminder that even mature compliance files can become outdated when new substances are added. (publicnow.com)
For exporters outside the EU, the most effective approach is to make SVHC data part of the commercial package: product specification, packing details, test evidence where relevant, and article-level chemical declarations. That helps EU importers meet their duties and reduces shipment delays caused by missing compliance evidence.
Frequently asked questions
Is SVHC compliance the same as REACH compliance?
No. SVHC compliance is one important part of REACH compliance, especially for articles. REACH also covers registration, restrictions, authorisation, safety data sheets and other duties. A product can pass an SVHC review and still require checks against REACH Annex XVII restrictions or other EU product rules.
Does the presence of an SVHC automatically ban a product?
Not necessarily. Candidate List inclusion usually triggers information, notification or reporting duties first. Some substances may later become subject to authorisation or restriction, but the compliance action depends on the substance, use, concentration, product type and legal role.
Can one supplier declaration cover all future shipments?
Only if it remains current and accurate. A declaration should be renewed or reconfirmed when the Candidate List changes, when materials or suppliers change, or when the buyer receives conflicting information. Long-term supply agreements should include a duty to notify material changes.
Does a non-EU exporter have to submit SCIP notifications?
In most cases, the EU supplier or importer is the direct SCIP duty holder. However, the non-EU exporter may need to provide article-level SVHC information so the EU party can complete its submission and communicate correctly downstream.
What is the safest first step for a new importer?
Begin with a component-level product map and supplier data request. Ask for Candidate List assessment by article, not just by finished product. Then review whether Article 33 communication, Article 7(2) notification or SCIP reporting may be triggered before the goods are placed on the EU market.
