REACH & SVHC declarations: what suppliers must communicate
How REACH SVHC communication works: what a Substance of Very High Concern is, the 0.1% weight threshold in articles, and the duties to inform customers (Article 33) and notify the ECHA SCIP database.
REACH, the EU regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (EC 1907/2006), places duties on companies that make, import, or supply substances, mixtures, and articles. For most manufacturers of finished products, the day-to-day obligation is about Substances of Very High Concern (SVHCs): knowing when one is present in what you sell, and communicating it down the supply chain. This guide covers what an SVHC is, the 0.1% threshold, and the communication duties.
What is an SVHC?
Substances of Very High Concern are substances identified under REACH as, for example, carcinogenic, mutagenic, toxic to reproduction, persistent and bioaccumulative, or of equivalent concern. ECHA maintains the SVHC “Candidate List”, which is updated roughly twice a year and grows over time. Being on the Candidate List is what triggers the communication duties below; a subset of SVHCs are later moved to the Authorisation List (Annex XIV), where use requires authorisation.
The 0.1% threshold in articles
For an article, meaning a manufactured object whose shape or design determines its function more than its chemical composition, the trigger is concentration. If a Candidate List SVHC is present in that article above 0.1% by weight (w/w), specific duties apply. Following the EU Court of Justice “once an article, always an article” ruling, the 0.1% is assessed at the level of each component article, not diluted across a whole assembly.
The 0.1% w/w threshold for SVHC communication is assessed per article. A small component above the limit brings the whole product into the communication and SCIP duties, even if the assembly’s overall percentage is far lower.
The duties when an SVHC is above 0.1%
| Duty | To whom | Basis |
|---|---|---|
| Provide safe-use information | Industrial / professional customers | REACH Article 33(1) |
| Provide information on request | Consumers, within 45 days, free | REACH Article 33(2) |
| Notify the substance in the article | ECHA SCIP database | Waste Framework Directive Art. 9(1)(i) |
In practice, suppliers meet the Article 33 duty with a REACH/SVHC declaration or statement that names any Candidate List substances present above the threshold and gives safe-use information. The SCIP notification to ECHA is a separate, database obligation. Both depend on knowing your product’s composition, which means collecting declarations from your own suppliers down the bill of materials.
RoHS, REACH and keeping declarations current
REACH is broader than RoHS: RoHS restricts ten substances in electronics, while REACH SVHC duties apply to substances in articles of all kinds, against a list that keeps growing. Our RoHS vs REACH comparison sets the two side by side. Because the Candidate List changes, a REACH declaration is a living document: it has to be reviewed against each list update and re-issued when your product’s status changes, which makes a controlled, version-controlled template far safer than a copied file. DataSheets Pro provides a structured starting point; determining which substances are present and which duties apply remains your responsibility.
Start from the templateREACH Declaration template: free & editable
Identify the product, reference the SVHC Candidate List and declare its status under REACH, then export a supplier-ready PDF, free to start.
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