REACH Compliance Explained: SVHC and Your Duties

A single cable tucked inside a product you didn't manufacture yourself can carry a chemical duty that lands squarely on your desk. REACH is the EU's chemicals regulation, and unlike CE marking rules that cover specific product categories, it reaches into almost every physical product sold in the EU, because it regulates substances rather than product types. As of February 2026, ECHA's Candidate List of Substances of Very High Concern runs to 253 entries, and if any one of them turns up above 0.1% by weight anywhere in what you sell, you have a legal duty to say so. Here is what that duty actually involves, and how to check it.

REACH vs RoHS: why the difference in scope trips people up

People who deal with electronics often meet RoHS first, and then assume REACH works the same way. It doesn't. RoHS restricts a fixed, short list of substances (lead, cadmium, mercury, certain flame retardants and phthalates) at set maximum concentrations, and it only applies to electrical and electronic equipment. Once you have checked your product against that list, following our RoHS compliance guide, you are largely done, until the list itself changes.

REACH is built differently. It covers virtually any chemical substance placed on the EU market, in virtually any kind of product, whether that's a toy, a piece of furniture, a garden hose or a laptop. Rather than one fixed list of banned substances, REACH works through several separate mechanisms: registration of substances manufactured or imported in volume, restriction of specific uses, authorisation for the highest-risk substances, and the Candidate List of SVHCs, which is the one that catches most ordinary manufacturers and importers off guard. A product can pass RoHS with no issues and still have a live REACH duty sitting inside a component nobody thought to check.

What is SVHC under REACH?

An SVHC, a Substance of Very High Concern, is a chemical that ECHA has formally identified as meeting one of several hazard criteria: it may cause cancer, damage fertility or an unborn child, persist in the environment while building up in living tissue, or disrupt hormones in a way judged equivalent in severity to those effects. Being named an SVHC is not the same as being banned outright. It is the trigger point for two things: eventual possible restriction or authorisation requirements down the line, and immediate communication and notification duties the moment the substance appears in your product above a set threshold. See our SVHC glossary entry for the formal criteria ECHA applies when assessing a candidate substance.

How the REACH Candidate List works, and why it keeps growing

ECHA and EU member states nominate substances for the Candidate List, and after a technical and public consultation process, ECHA's member state committee adds those that meet the criteria, usually twice a year. The list started with 15 substances in 2008 and had grown to 253 entries by 4 February 2026, when ECHA added n-hexane and bisphenol AF, according to SGS's coverage of the update. Because some entries cover whole groups of related chemicals rather than a single substance, the practical number of chemicals affected is larger still.

It helps to see how the Candidate List sits alongside REACH's other two lists, since people often use the names interchangeably when they mean quite different things.

The Candidate List is the one that matters for most consumer goods importers, because inclusion alone, with no further EU action needed, is enough to trigger your duties.

The 0.1% threshold: what you must notify and communicate

Once an SVHC is present above 0.1% weight by weight in an "article" (REACH's term for a manufactured item, as opposed to a substance or mixture), two separate duties can apply. Article 33 requires you to give downstream recipients, automatically, enough information to use the article safely, at minimum the substance's name, and to give the same information to a consumer who asks, free of charge, within 45 days. Article 7(2) adds a duty to notify ECHA directly if the substance is also present above one tonne per year across everything you place on the market, within six months of the substance's Candidate List listing date.

A 2015 ruling by the Court of Justice of the EU, often summarised as "once an article, always an article," settled a question that mattered a great deal in practice: the 0.1% figure is calculated against each individual component that itself counts as an article, not against the finished product as a whole. As Fieldfisher's analysis of the ruling explains, this means a tiny internal component can trigger the duty even though it is a negligible fraction of the finished product's total weight.

Say you're a UK-based brand selling a wireless charging pad assembled in Shenzhen. The charging pad itself is well under the threshold for any single substance, but the moulded cable running from the pad to the USB plug uses a PVC sheath containing a plasticiser, DEHP, at 0.3% weight by weight of that cable component. DEHP has been on the Candidate List for years. Because the calculation is done against the cable as its own "article," not against the whole charger, you would be over the 0.1% threshold and carrying an Article 33 duty, even though DEHP makes up a fraction of a percent of the finished product you actually sell.

There is also a data infrastructure layer to this. Since 5 January 2021, suppliers placing articles containing Candidate List substances above 0.1% w/w on the EU market have had to submit data to ECHA's SCIP database, which now holds more than 17 million notifications as of early 2026, according to Certivo's SCIP compliance overview. The same source notes that the European Commission's December 2025 Environmental Omnibus package has proposed eventually folding SCIP's function into the incoming Digital Product Passport, but until that change is formally adopted, the existing SCIP notification duty remains fully in force, so it is not something to deprioritise on the strength of a proposal.

Do I need a REACH compliance certificate or statement?

Not in the sense people usually mean it. There is no single official "REACH certificate" that ECHA or any government body issues, and no equivalent to the CE Declaration of Conformity that closes the matter with one signed document. What suppliers hand over as a "REACH statement" or "REACH compliance certificate" is normally a self-issued declaration, sometimes backed by lab testing, stating what the supplier knows about SVHC content in that specific product at that point in time. It is useful evidence to keep on file, and worth asking for before you commit to a production run, but it is not a legal guarantee, and it goes stale the moment the Candidate List updates, since a product can move from compliant to non-compliant with no change to the product itself. Compare this with the EU Declaration of Conformity, which is a formal, legally defined document tied to a specific set of harmonised legislation; REACH's SVHC duty works on an ongoing, self-monitoring basis instead.

Practical steps to check and document REACH compliance

The starting point is always the same: get a full material declaration from your supplier or factory, broken down by component, not just a one-line assurance that "the product is REACH compliant." From there, check each component against the current Candidate List, remembering that the list changes roughly twice a year, so a check done a year ago may already be out of date even if nothing about the product itself has changed.

• Calculate concentration per component ("the smallest demountable article"), not against the finished product's total weight, in line with the CJEU's 2015 ruling.
• If any component crosses 0.1% w/w for a listed SVHC, prepare the Article 33 communication text and check whether the one-tonne Article 7(2) and SCIP notification duties also apply.
• Keep supplier declarations, test reports and your own SVHC screening records on file, since market surveillance authorities can ask for them at any time, not just at the point of sale.
• Re-check the whole product line whenever ECHA updates the Candidate List, rather than only when you change a supplier or material.

If you are importing from overseas, our guide to what actually falls on you as an importer covers the documents worth asking your factory for before you pay, and REACH's SVHC evidence belongs on that same list alongside test reports and technical files. For a broader view of which chemical and product-safety rules apply to your specific product, our free requirements checker maps them against your product type and target markets.

REACH is not a box you tick once. It is a duty to keep knowing what is in your product and to say so when it matters, and the Candidate List is going to keep growing whether or not you are watching it. Building a habit of rechecking against the current list, rather than treating an old supplier declaration as permanent, is the difference between catching a problem before a customer or a market surveillance authority does, and finding out after.