What Should a REACH SVHC Compliance Statement Include for EU Buyers?

A REACH SVHC compliance statement may look like a small PDF in the shipment file, but it can decide whether an EU buyer releases the purchase order or sends the file back. If you sell articles, parts, packaging, tools, consumer goods, electronics, textiles, hardware, or mixed product kits into Europe, the statement should not stop at “REACH compliant.” It needs to tell the buyer what was checked, which list was used, and why your company can make the claim.

For import and export teams, this belongs with normal compliance paperwork. It is not just a document added at the end of the file. The European Chemicals Agency, known as ECHA, reported that the Candidate List contained 253 entries after its 4 February 2026 update. The list changes, and buyers know the date matters. A dated, product-specific statement helps when a retailer, distributor, or customs-linked compliance team asks for proof.

What Should a REACH SVHC Compliance Statement Include?

A useful statement answers the buyer’s first question without making them search: does the supplied article contain any Substance of Very High Concern from the current Candidate List above the legal reporting threshold? The document should be short enough to read quickly, but it still needs enough detail for a buyer audit.

Product and Supplier Scope

Start with the basic information. Name the supplier, product model, part number, product family, revision, and date of issue. If the statement covers a purchase order, batch, drawing revision, or SKU range, write that clearly. A statement for “all products” may look easy, but buyers often challenge it because materials can change by color, finish, adhesive, coating, or factory.

Current Candidate List Reference

State the Candidate List version used for the review. ECHA’s public Candidate List showed 253 entries in July 2026, and the most recent published addition was on 4 February 2026, when n-hexane and Bisphenol AF with its salts were added. This detail matters in daily trade work. A statement signed before a list update may not satisfy an EU buyer who checks files closely.

Clear Presence or Absence Claim

Use plain wording. For example, state that the listed products do not contain any Candidate List SVHC above 0.1% weight by weight in any article, based on available supplier data and test records. If an SVHC is present above the threshold, name the substance and provide safe-use information. Do not cover it with broad wording. Buyers see this problem often, especially when the same sentence appears in many supplier files.

When Does a Statement Become More Than a Simple Declaration?

A declaration is not always enough on its own. REACH creates communication and notification duties when SVHCs are found in articles above the threshold. Your statement should not try to replace those duties. It should show the evidence used and the actions already taken.

Article 33 Communication Above 0.1 Percent

EUR-Lex, the official EU law database, publishes REACH Regulation (EC) No 1907/2006. Article 33 says that a supplier of an article containing an SVHC above 0.1% weight by weight must give the recipient enough information for safe use, including at least the substance name. For consumers, the response must be given within 45 days of request and free of charge. That is why a buyer may ask for more than a one-line certificate.

Six-Month Notification Trigger for Importers

Under REACH Article 7(2), EU producers and importers may need to notify ECHA when a Candidate List substance is present above 0.1% w/w in articles and the total amount of that substance exceeds one tonne per year per producer or importer, unless exemptions apply. ECHA’s 4 February 2026 news release also reminded producers and importers that notification duties can start within six months from inclusion of the substance. For a non-EU exporter, this still matters because the EU buyer may need your data to decide whether the duty applies.

SCIP Reporting for EU Article Suppliers

Since 5 January 2021, the EU Waste Framework Directive has required suppliers of articles placed on the EU market to submit SCIP database information when those articles contain Candidate List SVHCs above 0.1% w/w. If your buyer is an EU importer, retailer, or assembler, your statement may feed directly into their SCIP submission. A vague declaration slows that work down. Clear article-level data helps the buyer enter the right information without coming back to you again and again.

How Should Exporters Build Reliable SVHC Evidence?

Good statements are prepared before the customer asks for them. Waiting until goods are packed is risky because SVHC checks often depend on answers from resin suppliers, metal finishers, dye houses, coating vendors, adhesive makers, and packaging converters. Some suppliers answer the same day. Some need repeated follow-up.

Bill of Materials Mapping

Map the bill of materials at article level. For a small appliance, that could mean the housing, cable, plug, screws, gasket, printed circuit board, label, coating, and packaging insert. The Court of Justice of the European Union ruled in case C-106/14 in 2015 that the 0.1% threshold applies to each article within a complex product, not only to the whole assembled product. So a small plastic grommet cannot be diluted by the weight of a steel frame.

Supplier Declarations With Dated Signatures

Collect declarations from material and component suppliers with dates, company names, substance list references, and authorized signatures. A supplier email saying “OK for Europe” is not enough for a serious buyer. Keep the original files in the order or compliance folder. A later audit may ask who gave the data, when they gave it, and which product revision it covered.

Targeted Testing for High-Risk Materials

Testing every substance in every part is usually not workable. Put the testing budget where the risk is higher: soft PVC, rubber, plasticizers, flame retardants, pigments, metal plating, leather treatments, textile coatings, adhesives, and recycled content. Test reports should support the statement, not replace supply chain data. A lab result from one black cable does not prove a red cable from another factory has the same chemical profile.

Can One Certificate Cover Every Shipment and Product?

Sometimes one statement can cover a stable product family. Often it cannot. EU buyers reject broad documents when the scope is too wide, the product range is mixed, or the date is old. It is dull paperwork, but it is still better than a container waiting while both sides argue over an outdated form.

Product Family Limits

You can group products when materials and suppliers are truly the same. For example, a stainless-steel bracket sold in three lengths may fit one statement if the alloy, coating, lubricant, packaging, and production site are unchanged. A product family with different colors, soft grips, glued parts, or printed coatings needs tighter control. If one small material changes, the old group statement may no longer be safe to use.

Candidate List Change Control

Review the statement after every Candidate List update. ECHA typically updates the list when substances are identified as SVHCs under REACH Article 59. Because new entries can create immediate Article 33 duties, a statement should carry a review date and an update trigger. Many companies use a January and July review cycle, with an extra review after any urgent customer request.

Lot and Revision Tracking

Link the statement to product revisions, not only to product names. If a coating changes from Supplier A to Supplier B, the old statement may no longer fit. Keep a simple log with the date, change, affected SKUs, supplier evidence received, and person responsible. It does not need to be fancy software. A controlled spreadsheet can save a lot of back-and-forth. See also: Customs.

What Mistakes Make Buyers Reject a REACH SVHC Compliance Statement?

Most rejections come from unclear scope, old list references, or claims that go beyond the evidence. A buyer is not always trying to make the supplier’s life hard. In many cases, they need your file to pass their own customer’s audit or an internal product compliance check.

Vague “REACH Compliant” Wording

REACH covers registration, evaluation, authorisation, restriction, safety data sheets, article communication, and more. A statement that only says “this product is REACH compliant” does not tell the buyer whether SVHCs were checked. Use the exact purpose of the document. Write it as a Candidate List SVHC assessment for articles against the 0.1% w/w threshold.

Missing Article-Level Assessment

Do not assess only the total finished product weight if the product is made of several articles. ECHA’s guidance on substances in articles follows the article-level approach. For trade teams, this means a screw, gasket, cable tie, printed label, or plastic handle may need its own check if it remains an article in the final product. This is where many shipment files fail during buyer review.

Old Documents After List Updates

A statement from 2023 may have been correct at the time, but it does not speak to the 2026 Candidate List. ECHA’s 4 February 2026 update is a good reminder that the list moves. Keep a validity period, such as 12 months or until the next Candidate List update, whichever comes first. If no reliable public data is available for a claimed list version, say that no verified source was found rather than guessing.

How Can You Use the Statement in Import and Export Trade?

The statement should help sales, shipping, and compliance teams work with fewer delays. It is not only a legal shield. It is a trade document that reduces repeated questions during quotation, sampling, order confirmation, shipment release, and annual supplier review.

Pre-Shipment Document Packs

Add the statement to the document pack with commercial invoice, packing list, test reports, product specification, and any requested declarations. For EU buyers, include REACH SVHC, RoHS if relevant, POPs if relevant, and packaging material statements where needed. Keep each claim separate. Mixing too many regulations into one unclear page usually creates more questions.

Buyer Audits and Retail Onboarding

Retailers and brand owners often ask for compliance files before the first order. The UK Government’s 2023 review of Article 33 duties found high awareness among surveyed suppliers, including 98% of 129 respondents knowing their duty to pass SVHC information through the supply chain. That data is from UK REACH, not EU REACH, but it shows the same commercial point. Buyers who know compliance work expect substance communication to be routine.

Practical Template Wording

A solid clause can read like this: “Based on supplier declarations, material records, and available test data, the products listed in this statement have been reviewed against the ECHA Candidate List of SVHCs published on the stated review date. No Candidate List SVHC is known to be present above 0.1% w/w in any article, unless listed in the exception table.” Add an exception table even if it is empty. It shows the buyer that exceptions were considered, not ignored.

• Include product names, model numbers, and revisions.
• State the Candidate List review date.
• Use the 0.1% w/w threshold per article.
• Name any SVHC above the threshold.
• Keep supplier evidence and test reports on file.

A good REACH SVHC compliance statement will not make a risky product safe by itself. It does show that you checked the right list, used the right threshold, and can answer buyer questions without panic. In export trade, that is often the difference between “approved” and “please resubmit.”

FAQ

Q1: Is a REACH SVHC Compliance Statement the Same as a Test Report? A: No. A statement is a supplier declaration based on evidence. A test report is one type of evidence, usually for selected materials or parts.

Q2: Does the 0.1% Threshold Apply to the Whole Finished Product? A: Not for complex products. The threshold should be assessed at article level, such as each component that remains an article in the final product.

Q3: How Often Should You Update the Statement? A: Update it after each Candidate List change, after a material or supplier change, and at least during your scheduled annual compliance review.

Q4: What if an SVHC Is Present Above 0.1% w/w? A: Name the substance, identify the affected article, provide safe-use information, and support the EU buyer’s Article 33 and possible SCIP duties.

Q5: Can a Non-EU Exporter Ignore SCIP? A: A non-EU exporter normally does not submit SCIP directly unless it has an EU role, but the EU buyer may need your article-level SVHC data for its submission.