REACH SVHC declarations: what hardware sellers owe

REACH gets bundled together with RoHS so often that people assume they're the same rule. They're not. RoHS bans specific substances above a fixed threshold in electronics; REACH's Substances of Very High Concern (SVHC) obligation is a disclosure and notification duty tied to a constantly-growing "Candidate List" that ECHA updates roughly every six months, and it applies more broadly than just electrical and electronic equipment.

The 0.1% threshold — assessed per component

If an article you supply contains a Candidate List substance above 0.1% weight-by-weight, Article 33 of REACH requires you to give your customer enough information to use it safely — at minimum, the name of the substance. The detail that catches hardware sellers off guard: for an assembled product, that threshold is assessed at the level of each individual component that is itself an "article," not against the finished product's total weight. A single connector, cable jacket or fastener at 0.5% SVHC concentration triggers the obligation even if it makes up a fraction of a percent of the whole device's mass — this is sometimes called the "once an article, always an article" principle.

Two separate duties, two separate triggers

• Article 33 (supply-chain disclosure) — triggers per article above 0.1% w/w, with no minimum quantity. If asked, you must provide the SVHC information to a consumer free of charge within 45 days.
• Article 7(2) (ECHA notification) — a separate, higher-threshold duty: EU/EEA producers or importers of articles must notify ECHA directly if a Candidate List substance is present above 0.1% w/w *and* the total quantity across all your articles containing it exceeds one tonne per year. Notification is due within six months of the substance's addition to the list.

Most small hardware sellers will hit the Article 33 disclosure duty well before they hit the one-tonne notification threshold — but if you're scaling production, the tonnage clock is worth tracking.

The Candidate List keeps growing

As of the most recent update, the Candidate List runs to around 250 substances, and ECHA revises it roughly twice a year. A component that cleared REACH screening at launch can fall out of compliance eighteen months later purely because ECHA added a substance your supplier uses — this is why REACH screening has to be a recurring check, not a one-time sign-off before your first shipment.

Building the check into your process

• Get supplier declarations that specifically reference the current Candidate List version, not a generic "REACH compliant" statement with no substance list attached.
• Re-screen your bill of materials against the Candidate List on each ECHA update cycle, particularly for connectors, cables, solder and plastics — the components most likely to carry legacy flame retardants or plasticisers.
• Keep your SVHC disclosure ready to hand to a customer on request — the 45-day free-disclosure clock starts the moment they ask, not when you get around to compiling it.

REACH SVHC screening sits alongside RoHS in your technical file — the two overlap on some substances (like phthalates) but have different thresholds and different triggers, so passing one doesn't automatically clear the other.