If you place articles (physical products) on the EU market, certain REACH requirements when your product contains SVHCs (Substances of Very High Concern) or restricted substances. The biggest compliance risk isn’t “REACH in general”—it’s missing an obligation because you treated a complex product as one object instead of assessing its components.
If you place articles (physical products) on the EU market, REACH can create legal obligations when your product contains SVHCs (Substances of Very High Concern) or restricted substances. The biggest compliance risk isn’t “REACH in general”—it’s missing an obligation because you treated a complex product as one object instead of assessing its components.
This guide explains:
how REACH defines an article,
the key “substances in articles” obligations (Article 33 and Article 7),
how the ECHA guidance supports implementation, and
how SCIP reporting fits in (separate legal basis, but linked in practice).
REACH defines an article as an object whose shape, surface, or design determines its function more than its chemical composition.
In practice, articles include most finished goods and components (e.g., housings, cables, connectors, labels, PCBs as components, etc.).
The table below summarizes common scenarios and associated obligations for substances in articles:
The REACH requirements are legal provisions under Regulation (EC) No 1907/2006. The obligations for substances in articles focus on ensuring the safety and traceability of chemicals incorporated into products. Consequently, these requirements address substances that may endanger human health or the environment. The regulation applies to all companies placing articles on the European market. Failure to comply with REACH requirements may result in penalties, restricted market access, or reputational harm.
Manufacturers and importers must address obligations depending on the presence and concentration of certain substances in their articles. The following highlights the main requirements:
Obligation | Legal Basis | Substances Concerned | Thresholds |
|---|---|---|---|
Communication of information on substances in articles (via SCIP database) | REACH Article 33 | Substances included in the Candidate List of SVHC | Concentration > 0.1% w/w in article
No tonnage threshold |
Notification of substances in articles (to ECHA) | REACH Article 7(2) | Substances included in the Candidate List of SVHC | 1 tonne/year and concentration > 0.1% w/w in article |
Registration of substances in articles | REACH Article 7(1) | Substances intended to be released from articles under normal or reasonably anticipated usage conditions | 1 tonne/year per SVHC |
Restriction of substances | REACH Annex XVII | Various hazardous chemicals in certain materials and applications | Varies |
Suppliers must inform customers if their articles contain Candidate List Substances of Very High Concern (SVHCs) above a concentration of 0.1% weight-by-weight (w/w), component level.
Importantly, this obligation applies regardless of the volume of goods sales or the quantity of SVHC placed on the market, even below 1 tonne.
The information must include the substance name and guidance on safe use. This communication ensures that customers and end-users are aware of potential risks. Accordingly, suppliers must submit information about these articles to the SCIP (Substances of Concern In Products) database. This database, maintained by the European Chemicals Agency (ECHA), ensures transparency for consumers and waste operators regarding the presence of hazardous substances in products throughout their lifecycle. Additionally, ECHA updates the Candidate List approximately every six months as it identifies new SVHCs.
Additionally, to the communications obligation above, producers or importers must notify the ECHA if:
Notification ensures that ECHA and Member States are aware of the presence of these substances for further regulatory actions if needed.
Further, if SVHCs are intentionally released from an article (e.g., scented candles or printer cartridges) during its normal or reasonably anticipated conditions of use, manufacturers must register these chemicals with ECHA, above 1 tonne per year. The registration process requires detailed information about the substance and its safe use.
On top of the obligations above, we should not forget the REACH restrictions of hazardous chemicals per Annex XVII. For example, Nikel is restricted when indirect prolonged contact with the skin.
European Chemicals Agency (ECHA) publishes guidance to help producers and importers determine their obligations—especially around Article 7 (registration/notification) and Article 33 (supply-chain communication) for SVHCs in articles.
Complex objects are products made up of multiple articles. According to REACH, manufacturers must evaluate every component within a complex object separately for compliance. For example, components of a smartphone include the battery, casing, flexible cables and connectors as individual articles. Therefore, the supplier must assess every component for SVHCs exceeding 0.1% w/w and any associated obligations.
If an article contains a Candidate List SVHC above 0.1% w/w, suppliers must provide recipients with sufficient information to allow safe use (and, on request, provide consumer information within the required timeframe).
No tonnage threshold applies to Article 33 communication.
You may need to notify ECHA if:
an article contains a Candidate List SVHC > 0.1% w/w, and
the SVHC exceeds 1 tonne/year across all articles placed on the EU market by that actor (with some exemptions).
If a substance is intended to be released from an article under normal or reasonably foreseeable conditions of use, registration may apply (typically above 1 tonne/year per substance).
Separate from SVHC communication/notification, REACH restrictions under Annex XVII can prohibit or limit certain substances in specific materials and uses (e.g., consumer-contact scenarios).
The SCIP database is managed by ECHA, but it is established under the EU Waste Framework Directive (not REACH). It requires suppliers to submit information when Candidate List SVHCs are present above 0.1% w/w in articles placed on the EU market.
In practice, companies manage REACH Article 33 + SCIP together because both depend on:
Candidate List SVHC identification, and
component/article-level concentration assessment.
Define the article tree (finished product → sub-assemblies → components/articles).
Request supplier declarations (SVHC + Annex XVII) at the component/material level.
Evaluate Candidate List SVHCs and apply the 0.1% w/w threshold at the article/component level.
Article 33 communication (if >0.1% w/w),
Article 7 notification (if >0.1% w/w + >1 tonne/year),
SCIP submission (if applicable under WFD),
Annex XVII restrictions check.
Candidate List updates occur regularly; build a monitoring cadence and revision log.
For SVHCs, the 0.1% w/w threshold is assessed at the article/component level for Article 33 communication, consistent with EU interpretation for complex objects.
No. SCIP is under the Waste Framework Directive, but it uses the Candidate List SVHC trigger and is administered by ECHA—so companies often manage them together.
Not always. Notification under Article 7(2) generally requires both >0.1% w/w and >1 tonne/year (with certain exemptions).
You still assess SVHCs and thresholds at the component/article level. This is often the hardest part operationally because it requires supplier-level traceability.
Annex XVII restrictions can apply even when SVHC thresholds are not triggered; they are use- and material-specific limits/bans.
Enviropass can help you meet REACH requirements by assisting with compliance assessments and SCIP database submissions. Contact us!