REACH SVHC Declarations: What the 2019 ECHA Enforcement Project Found
Historical enforcement data
The statistics on this page come from an ECHA enforcement project published in 2019. They remain useful as an example of supply-chain communication failures but should not be interpreted as current 2026 market-wide failure rates.
For the current Candidate List and present REACH requirements, see our REACH SVHC compliance guide.
What Did ECHA Inspect?
The pilot project focused specifically on articles considered relatively likely to contain targeted Candidate List substances.
The 682 articles inspected included:
- wires, cables and electronic accessories;
- plastic and rubber products;
- clothing, footwear and home textiles;
- plastic or textile flooring; and
- wall coverings.
This is an important limitation when interpreting the results: the products were not selected as a representative sample of all goods placed on the European market. Inspectors deliberately focused on products considered more likely to contain the substances being targeted.
Nevertheless, the findings provide a useful illustration of the challenges companies can face when obtaining and communicating reliable SVHC declarations.
What Did Inspectors Find?
Of the 682 articles inspected, 84 contained one or more Candidate List substances above the 0.1% w/w concentration threshold.
That represents approximately 12% of the articles checked.
The more striking finding, however, concerned communication within the supply chain.
For 45 articles where the REACH business-to-business communication obligation applied, suppliers failed to provide the required information in 40 cases—approximately 89%.
ECHA also reported that 37 out of 42 companies, or approximately 88%, failed to communicate the name of the Candidate List substance to recipients of their articles.
This distinction is important. The finding does not mean that 88% of all products inspected failed REACH. Rather, it shows a high failure rate among the subset of companies and articles for which the applicable SVHC communication obligation was examined.
What Does REACH Article 33 Require?
Under Article 33 of REACH, suppliers of articles containing a Candidate List substance above 0.1% w/w must provide recipients with sufficient information to allow the article to be used safely. Reliable SVHC declarations should identify the applicable article, relevant substance information and sufficiently current regulatory scope.
At a minimum, the name of the Candidate List substance must be communicated. This obligation applies as soon as the substance is included in the Candidate List. Consumers also have the right to request similar information. When a consumer makes such a request, the supplier must provide the relevant information free of charge and within 45 days.
Which Substances Were Found?
The ECHA enforcement project identified several substances and substance groups relevant to product compliance.
These included substances such as:
- phthalates, including DEHP;
- short-chain chlorinated paraffins (SCCPs);
- lead;
- cadmium;
- Bisphenol A (BPA);
- brominated flame retardants; and
- other Candidate List substances.
ECHA noted particular concerns involving materials such as soft plastics and rubber, which can contain plasticizers, stabilizers, flame retardants and other additives.
For electronics manufacturers, these are also materials that frequently justify additional attention during a REACH product assessment.
Why Supplier Declarations Can Be a Weak Point
The enforcement findings illustrate a broader challenge in REACH compliance: obtaining a document is not necessarily the same as obtaining adequate compliance evidence.
A supplier statement may be insufficient when it:
- does not identify the applicable Candidate List version;
- does not cover the exact part number supplied;
- provides no information about substances above 0.1% w/w;
- relies on outdated information;
- does not identify the substance concerned; or
- cannot be traced to the actual manufacturer or material.
This problem remains relevant today.
Enviropass 2026 Project Data
Approximately 30% of the REACH projects in Enviropass’s January–August 2026 portfolio required additional supplier follow-up because the available declaration was incomplete, outdated or insufficiently specific.
This does not represent the same population or methodology as the 2019 ECHA enforcement study. Rather, it provides a separate, current observation from Enviropass project experience showing that supplier documentation remains an important practical challenge in REACH assessments.
See the full 2026 Product Environmental Compliance analysis.
Source: Enviropass Expertise Inc., 2026 Product Compliance Project Portfolio, January–August 2026.
What Should Manufacturers Do?
A defensible REACH compliance process should go beyond collecting generic declarations.
For each relevant component or material, companies should consider whether:
- the manufacturer and part number are clearly identified;
- the declaration applies to the exact supplied article;
- the document references an appropriate and sufficiently current Candidate List;
- substances above the applicable threshold are properly identified;
- Article 33 communication requirements have been addressed;
- supporting test reports or material information are available where documentation is insufficient; and
- changes in suppliers, materials or the Candidate List trigger a new review.
For complex electronic products, a structured bill of materials and reliable supplier cross-references make this process considerably easier.
Why the 2019 Enforcement Findings Still Matter
The ECHA pilot project is historical, but its main lesson remains relevant:
REACH compliance depends heavily on the quality of information communicated through the supply chain.
The presence of a declaration alone does not demonstrate that the information is complete, current or applicable to the product being assessed.
This is why Enviropass treats supplier documentation as evidence to be reviewed and validated, rather than simply collected.
Need Help Assessing REACH Compliance?
Enviropass can review product BOMs, supplier declarations, full material disclosures and test evidence to identify gaps and determine whether additional supplier follow-up or analytical testing is appropriate.
Regulatory Sources
- European Chemicals Agency (ECHA) — Forum pilot enforcement project on substances in articles, published November 18, 2019. ECHA reported inspections of 405 companies and 682 articles, with 84 articles containing Candidate List substances above 0.1% w/w.
- European Chemicals Agency (ECHA) — Communication in the supply chain under REACH Article 33.
Last technical review: September 2026
For information on how Enviropass reviews regulatory content and selects sources, see our Editorial Policy.
