SVHC: substances of very high concern under EU REACH, and what the 0.1% rule asks of your products

SVHC stands for substance of very high concern. It is a REACH term, Regulation (EC) No 1907/2006Regulation (EC) No 1907/2006, REACH (chemicals)The whole regulationClick opens the law on the EU Publications Office.: REACH is the law, and an SVHC is one kind of substance it controls (Art. 55Regulation (EC) No 1907/2006, REACH (chemicals)Article 55Click opens the article on EUR-Lex.). A substance becomes an SVHC for your products the day ECHA adds it to the Candidate List (Art. 59(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 59, paragraph 1Click opens the article on EUR-Lex.). The list does not ban the substance. It makes everyone who supplies an article containing it pass information down the chain.

What makes a substance an SVHC: the six REACH criteria

A substance can be identified as an SVHC if it meets one of these criteria (Art. 57Regulation (EC) No 1907/2006, REACH (chemicals)Article 57Click opens the article on EUR-Lex.). The first three rest on the hazard classes of the EU CLP Regulation, Regulation (EC) No 1272/2008Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027The whole regulationClick opens the law on the EU Publications Office..

A dossier is prepared by an EU country or, at the Commission’s request, by ECHA. It goes out for comment, and the substance joins the list either unopposed, by unanimous agreement of ECHA’s Member State Committee, or by a Commission decision (Art. 59(2)-(9)Regulation (EC) No 1907/2006, REACH (chemicals)Article 59, paragraphs 2 to 9Click opens the article on EUR-Lex.). ECHA publishes and updates the list on its website “without delay” after each inclusion (Art. 59(10)Regulation (EC) No 1907/2006, REACH (chemicals)Article 59, paragraph 10Click opens the article on EUR-Lex.).

How many substances the Candidate List holds

On 5 October 2026 ECHA’s chemicals database, ECHA CHEM, listed 253 entries on the Candidate List. The latest two were included on 4 February 2026: n-hexane, for specific target organ toxicity after repeated exposure, and 4,4’-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts, as toxic for reproduction. Before that, 1,1’-(ethane-1,2-diyl)bis[pentabromobenzene] was added on 5 November 2025.

An entry can be a single substance or a group, such as a substance “and its salts”. Your supplier’s statement should cover the whole entry, not only the substance it names first.

Three REACH lists are easy to mix up. Only the first is the SVHC list.

Great Britain keeps its own list. HSE publishes the UK REACH Candidate List under UK REACH. HSE states that UK REACH regulates chemicals placed on the market in Great Britain, and that EU REACH continues to apply in Northern Ireland. This page covers the EU list.

The 0.1% counts in each article inside your product

REACH counts the 0.1% “weight by weight” in the article (Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex.). An article is an object whose shape, surface or design decides its function more than its chemical composition does (Art. 3(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 3Click opens the article on EUR-Lex.). Most products are built from several of them.

The Court of Justice settled how to count in 2015. An object that meets that definition “does not cease to be an article when it is assembled or joined with other objects in order to form with them a complex product”. It stays an article as long as it keeps the shape, surface or design that decides its function, or until it becomes waste (Case C-106/14, paragraphs 53 and 54). The rule is known as “once an article, always an article”.

So the supplier of a product must inform its buyers, and consumers who ask, when “one or more constituent articles” hold an SVHC above 0.1% “of that article” (Case C-106/14, operative part, point 2). An importer of a product made of several articles checks each one for the ECHA notification as well (Case C-106/14, operative part, point 1).

If the charger’s cable holds a Candidate List substance above 0.1% of the cable’s weight, the duty applies, even when the whole charger is far below 0.1%.

What an SVHC above 0.1% makes you do

Every duty below starts from the same fact: an article holding a Candidate List substance above 0.1% by weight.

Who counts as whom. A “recipient of an article” is a business or professional user, or a distributor; it “does not include consumers” (Art. 3(35)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 35Click opens the article on EUR-Lex.). That is why a consumer gets the information on request only. A retailer is a supplier of an article like any other (Art. 3(33)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 33Click opens the article on EUR-Lex.).

When it starts. Art. 33Regulation (EC) No 1907/2006, REACH (chemicals)Article 33Click opens the article on EUR-Lex. sets no grace period. ECHA states that the obligations are effective “from the date of inclusion” on the Candidate List. Only the ECHA notification waits six months (Art. 7(7)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 7Click opens the article on EUR-Lex.).

Who sends SCIP data. The Directive names “any supplier of an article” and points to the information owed under Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex. (Art. 9(1)(i)Directive 2008/98/EC, Waste Framework DirectiveArticle 9, paragraph 1, point (i)Click opens the article on EUR-Lex. of Directive 2008/98/EC). ECHA reads that as EU producers and assemblers, EU importers, EU distributors and other actors placing articles on the market. It states that “Retailers and other supply chain actors supplying articles directly and exclusively to consumers are not covered by the obligation to provide information to the SCIP database”, and its requirements document adds that retailers who are importers or producers are covered (ECHA, Requirements for SCIP notifications, sections 1.2 and 1.3). Who files, and what the notification holds, is in the SCIP database guide. ECHA runs the database and opens it to waste treatment operators and, on request, to consumers (Art. 9(2)Directive 2008/98/EC, Waste Framework DirectiveArticle 9, paragraph 2Click opens the article on EUR-Lex. of Directive 2008/98/EC). Each EU country writes the duty into its own law.

The ECHA notification counts the substance, not the goods. The tonne is the substance across all your articles in a year. The notification names you, the substance, its classification, its use in the article and a tonnage range (Art. 7(4)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 4Click opens the article on EUR-Lex.). No notification is due where you can exclude exposure to people and the environment during normal or reasonably foreseeable conditions of use, including disposal; you then give the recipient instructions instead (Art. 7(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 3Click opens the article on EUR-Lex.). None is due where the substance is already registered for that use (Art. 7(6)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 6Click opens the article on EUR-Lex.).

If you sell from outside the EU

REACH places its import duties on an “importer”: a person “established within the Community who is responsible for import” (Art. 3(11)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 11Click opens the article on EUR-Lex.). Import, the physical arrival of the goods in the EU customs territory, counts as placing them on the market (Art. 3(10)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 10Click opens the article on EUR-Lex., Art. 3(12)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 12Click opens the article on EUR-Lex.). A business outside the EU cannot be that importer. What it can do is hand its EU importer what the importer needs.

REACH is on the list of Union harmonisation legislation in Annex I to Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office., point 22, so that Regulation’s market surveillance rules apply to articles under REACH (Art. 2(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 2, paragraph 1Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020). The only representative route of Art. 8(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 1Click opens the article on EUR-Lex. and the full map of who imports are set out in REACH compliance and importer of record in the EU.

When you sell the substance or a mixture, not an article

A Candidate List substance sold on its own needs a safety data sheet for each business you supply (Art. 31(1)(c)Regulation (EC) No 1907/2006, REACH (chemicals)Article 31, paragraph 1, point (c)Click opens the article on EUR-Lex.). A mixture that is not classified as hazardous needs one on request when it holds a Candidate List substance at 0.1% by weight or more, for a non-gaseous mixture (Art. 31(3)(b)Regulation (EC) No 1907/2006, REACH (chemicals)Article 31, paragraph 3, point (b)Click opens the article on EUR-Lex.). The safety data sheet guide covers both.

What happens if you do nothing

Each EU country sets the penalties for breaking REACH, and they must be “effective, proportionate and dissuasive” (Art. 126Regulation (EC) No 1907/2006, REACH (chemicals)Article 126Click opens the article on EUR-Lex.). The SCIP duty comes from a directive, so each EU country sets its penalties under that directive, on the same terms (Art. 36(2)Directive 2008/98/EC, Waste Framework DirectiveArticle 36, paragraph 2Click opens the article on EUR-Lex. of Directive 2008/98/EC). Leaving a consumer without an answer after 45 days, or supplying a business without the SVHC information, breaks Art. 33Regulation (EC) No 1907/2006, REACH (chemicals)Article 33Click opens the article on EUR-Lex.. Your business buyer also needs that information to meet its own SCIP duty.

What you can skip

What the law leaves open

• Who the importer is when a parcel goes from outside the EU straight to an EU consumer. Art. 3(11)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 11Click opens the article on EUR-Lex. requires the importer to be in the EU, and a consumer buying for personal use supplies no one. No article of REACH names who carries the importer duties on that route. Meanwhile, keep the SVHC statements and answer consumer requests within 45 days.
• How much information is “sufficient” for safe use. Art. 33Regulation (EC) No 1907/2006, REACH (chemicals)Article 33Click opens the article on EUR-Lex. sets the substance name as the minimum and adds information “available to the supplier”. The text does not list what else. Meanwhile, give the name, the part that holds it, and any handling or disposal advice your supplier gives you.