Ultimate REACH SVHC Guide: What Companies Should Know

Q: In what way could the Annex XVII list differ from the Candidate List of SVHCs?

Main differences:– SVHC Candidate List: information and notification obligations.– Annex XVII: Prohibitions or Concentration Limits.A substance can be listed in Annex XVII even if it is not an SVHC, and an SVHC can be listed in Annex XVII.

Q: How often should SVHC and Annex XVII compliance be reviewed?

The following aspects of compliance can be checked:– every time that the Candidate List of SVHCs is updated by ECHA – when Annex XVII restrictions are amended, – when suppliers, materials, or manufacturing processes change.

If you manufacture, import, or distribute products in the European Union, REACH SVHC compliance is not a box you check once and forget. The Candidate List evolves, supplier declarations become outdated, and a small misunderstanding about thresholds can quickly become a customer issue, a SCIP issue, or a market-access issue. Today, the Enviropass REACH SVHC page provides access to the current REACH 253 SVHC Table and the Annex XVII restriction list, helping you work from the latest available references.

REACH SVHC and Annex XVII Current Lists

REACH compliance starts with the right references. The Enviropass page currently offers downloadable versions of the SVHC Candidate List and Annex XVII restrictions list in both PDF and Excel formats so your team can work with current substance data in the format that best fits your internal process.

The distinction matters. The Candidate List identifies substances of very high concern, while Annex XVII restricts certain hazardous substances in specific uses, mixtures, and articles. A product may therefore have no Article 33 communication issue and still fail REACH because of an Annex XVII restriction. That is why we recommend screening both lists together instead of treating REACH as a single-list exercise.

You can also consult the Current ECHA Candidate List of SVHCs for the official regulatory source alongside our downloadable REACH SVHC table.

Example of Common SVHCs

To illustrate why ongoing monitoring matters, here are examples of substances highlighted in recent SVHC update content and the kinds of applications where they may appear. The list changes over time, which is why companies need a repeatable review process rather than a one-time declaration exercise.

Substance	Main concern	Examples of where it may appear
EGDME	Reproductive toxicity	Solvents and chemical formulations
Lead	Reproductive toxicity	Alloys, solders, metal parts, electronics components
PFHxS and its salts	Persistent and bioaccumulative concern	Certain specialty chemical and fluorinated applications
SCCPs	PBT / vPvB concern	Plastics, rubber, coatings, industrial formulations

The Enviropass Approach to REACH Compliance

At Enviropass, we help you turn REACH obligations into a practical compliance process. That includes reviewing supplier documentation, identifying at-risk materials, validating declarations, supporting testing when needed, and helping you understand when Article 33 communication, SCIP notification, or additional ECHA notification may apply. The goal is not just to find substances of very high concern. The goal is to make sure your products remain compliant as the rules and substance lists continue to evolve.

Testing every part for every possible substance is rarely the best starting point. The current Enviropass page positions REACH support around a documentary approach first, followed by targeted validation where risk justifies it. This method helps control cost while keeping your compliance file usable as the Candidate List grows.

In practice, that means we begin by collecting supplier and subcontractor documentation, reviewing declarations for quality and completeness, comparing disclosed substances against the latest Candidate List and Annex XVII entries, and identifying where clarification or testing is actually needed. This is usually a more efficient route than launching dozens of analyses without first understanding where the risk really sits.

When laboratory work is needed, we can support testing of product parts against at-risk substances from both the SVHC list and Annex XVII. That is especially useful when supplier information is incomplete, when high-risk materials are involved, or when customers require stronger evidence than a generic supplier statement.

REACH Testing Lab

Test your product parts against the at-risk substances from the EU REACH SVHC list and Annex XVII.

Classic REACH SVHC

By using Classic REACH, you allow Enviropass to undertake the documentary assessment of your products, including:

Up-to-date data collection with your suppliers/subcontractors;

Quality validation of documents and risk analysis;

Preparation of analysis results and certificates of compliance.

You can access REACH and RoHS testing services together at a bundled rate!

Deluxe EU RoHS

In addition to the Classic REACH service, Deluxe REACH gives you the tools to take control of REACH compliance. Deluxe REACH includes:

Customized training on products auditing, allowing you to conduct the analyses and to update yourself on the declarations of conformity (DoC);

Auditing your REACH risk assessments.

Online REACH Training

A unique online training on EU REACH, SVHC, and SCIP compliance is now available!

What is the EU REACH Regulation?

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is the European regulatory framework for managing chemical risks and protecting human health and the environment. The current Enviropass page correctly points to Regulation (EC) No 1907/2006 as the legal foundation.

For product companies, REACH matters because it applies not only to substances on their own and in mixtures, but also to many finished goods classified as articles. That broad scope is one reason REACH affects industries as varied as electronics, medical equipment, furniture, batteries, instruments, hardware, packaging, adhesives, and coated parts.

Does REACH SVHC Apply to Your Product?

In most cases, yes. REACH obligations can apply to substances, mixtures, and articles placed on the EU market. For manufactured goods, the main question is usually whether the product contains Candidate List substances above the legal threshold and whether any restrictions apply under Annex XVII. Packaging may also need to be reviewed depending on product configuration and market expectations.

That means REACH is relevant well beyond traditional chemical products. A finished device, a cable assembly, a furniture component, a battery pack, a coated fastener, or a molded plastic part may all create REACH obligations depending on material content and intended use. A good compliance review therefore needs to look at the product structure, not just the commercial product name.

What Are SVHCs Under REACH?

SVHC stands for Substances of Very High Concern. These substances are placed on the Candidate List because of serious hazard properties such as carcinogenicity, mutagenicity, reproductive toxicity, persistence, bioaccumulation, or endocrine-disrupting effects. Enviropass’s current page also notes that the list is updated regularly, typically every six months.

That update cycle is one of the biggest practical challenges for manufacturers and importers. A declaration that looked fine a few months ago may need to be reviewed again after a new Candidate List update. For that reason, a technical file should be treated as a living compliance record rather than a static certificate stored and forgotten.

EU REACH SVHC Obligations

For articles, the most important SVHC trigger is the 0.1% weight-by-weight threshold at article level. The current Enviropass page explains that when an SVHC is present above 0.1% in an article, information must be communicated to customers and consumers, and additional obligations may apply depending on the circumstances. It also notes that if the total amount of the substance exceeds one tonne per producer or importer per year, ECHA notification may be required.

This is where many companies oversimplify REACH. The question is not only whether an SVHC exists somewhere in the finished product. The real questions are: in which article is it present, at what level, in what yearly volume, and what documentation supports that conclusion? Those details determine whether you are dealing with Article 33 communication, SCIP notification, Article 7(2) notification considerations, or only internal monitoring.

Trigger	What it means	Possible next step
SVHC on the Candidate List	Substance must be assessed against current list status	Update your screening and supplier review
Above 0.1% w/w in an article	Article 33 communication duties may apply	Provide required safe-use information
Article placed on the EU market with SVHC above 0.1% w/w	SCIP may apply	Prepare or update SCIP submission
Total SVHC amount above 1 tonne/year per producer or importer	Article 7(2) notification may need review	Assess ECHA notification obligations
Substance restricted under Annex XVII	Product may face use-specific restrictions	Confirm the product is still marketable

The 0.1% Rule and the “Once an Article, Always an Article” Principle

One of the most important REACH concepts for finished goods is that the 0.1% threshold is assessed at the article level. The current Enviropass page states that since the 10 September 2015 Court of Justice of the European Union decision, producers must disclose SVHCs above 0.1% w/w in every article that makes up a product. This is often summarized as “once an article, always an article.”

In practical terms, that means a component does not lose its status as an article just because it becomes part of a larger assembly. A cable, connector, housing, coated bracket, gasket, button, or plastic insert may need to be assessed individually. If you average the substance content across the total finished product, you can easily miss a real obligation.

Scenario	Incorrect approach	Correct REACH approach	Compliance impact
Complex finished product with many components	Assess the total product	Assess each relevant article separately	You may miss an SVHC above 0.1% in one component
Laptop, instrument, or control unit	Average concentration over the full assembly	Review battery, cable, housing, connectors, display, and other articles individually	Article 33 and SCIP may still apply
Product sourced from multiple suppliers	Accept one broad declaration	Collect article-level data where needed	Stronger traceability and audit readiness
Product redesign or material change	Reuse old declaration without review	Reassess affected articles and update file	Better change control

This is exactly why generic declarations often create trouble. To support a defensible REACH position, supplier information should be specific enough to identify the relevant article, the declared substances, and the basis for compliance.

The SCIP Notification of REACH SVHC

SCIP stands for Substances of Concern In articles, as such or in complex objects (Products). ECHA’s SCIP database covers articles and complex objects containing Candidate List substances above 0.1% w/w, and the current Enviropass page notes that SCIP obligations have applied since January 5, 2021 for newly sold products in scope.

Many companies discover SCIP too late because they focus only on supplier declarations. In reality, SCIP depends on the quality of the product breakdown behind the declaration. If article boundaries are unclear, if concentrations are vague, or if supplier data is outdated, the submission process becomes much harder than it needs to be.

At Enviropass, we recommend handling SCIP as part of the broader REACH process rather than as a separate administrative task. The same product intelligence used for SVHC review can support SCIP submissions, supplier follow-up, change management, and future updates when the Candidate List changes.

What is Considered an Article under EU REACH?

The REACH definition of an article focuses on whether an object’s shape, surface, or design determines its function more than its chemical composition. That definition matters because many of the obligations discussed above apply specifically at article level. The current Enviropass page quotes the Article 3(3) definition and uses it as the basis for the “once an article, always an article” interpretation.

For manufacturers and importers, this is often the point where compliance becomes operational rather than theoretical. A product must be broken down into meaningful article-level units before the 0.1% threshold, SCIP reporting logic, and supply-chain data requests can be applied correctly.

The REACH Annex XVII Restrictions List

Annex XVII is separate from the SVHC Candidate List and should not be treated as an afterthought. The current Enviropass page already highlights this distinction and gives the example of nickel and its compounds in parts intended for direct and prolonged skin contact. That is a good reminder that a product can have no SVHC declaration problem and still be non-compliant because of a restriction.

This is why a proper REACH review should include both SVHC communication logic and restriction screening. If your product includes coatings, metal finishes, polymers, adhesives, textiles, consumer-contact surfaces, or specialty materials, Annex XVII deserves the same attention as the Candidate List.

REACH Record Keeping and Non-Compliance Risk

The current Enviropass page notes that REACH information must be retained for at least ten years after the last article is placed on the EU market. That requirement reinforces the need for organized technical files, change records, supplier declarations, and supporting evidence. A declaration without a traceable basis is much less useful when customers or authorities ask follow-up questions years later.

The page also notes that non-compliant products can face market withdrawal or recalls. In practice, poor documentation can create risk even before a lab issue is discovered, because an incomplete or outdated file can undermine your ability to defend a compliance claim.

REACH Services from Enviropass

At Enviropass, we support companies with both hands-on compliance execution and internal capability building. The live page presents two main service paths: a Classic REACH approach focused on documentary assessment, supplier follow-up, validation, and compliance deliverables, and a Deluxe REACH approach that adds customized training and auditing support so your team can manage more of the process internally.

For companies that want a structured starting point, the page also promotes a free consultation, laboratory testing support, and an online training course on EU REACH, SVHC, and SCIP compliance. This is the right positioning for the page, because many visitors are not looking only for information. They are looking for a practical next step.

FAQ on REACH Obligations to Articles

What is the SCIP database?

SCIP (Substances of Concern In articles as such or in complex objects) is a database under the ECHA governed by the Waste Framework Directive. It is required that any firm submitting articles with restricted substances above the value of 0.1 percent on the EU market is to inform SCIP.

In what way could the Annex XVII list differ from the Candidate List of SVHCs?

Main differences:
– SVHC Candidate List: information and notification obligations.
– Annex XVII: Prohibitions or Concentration Limits.
A substance can be listed in Annex XVII even if it is not an SVHC, and an SVHC can be listed in Annex XVII.

Is Annex XVII relevant to articles?

Yes. Many Annex XVII entries specifically include articles, such as:
– lead in consumer articles,
– phthalates in plastics,
– PFAS in textiles, chemicals, and other substances,
– nickel release from metal parts in skin contact.

Is analytical testing mandatory under REACH SVHC or Annex XVII?

Testing is not specifically mandatory. It becomes mandatory under the following circumstances:
– suppliers are unable to produce valid declarations,
– high-risk materials are involved (plastics, coatings, solders, rubbers),
– enforcement, audits, or market surveillance are expected.

How often should SVHC and Annex XVII compliance be reviewed?

The following aspects of compliance can be checked:
– every time that the Candidate List of SVHCs is updated by ECHA
– when Annex XVII restrictions are amended,
– when suppliers, materials, or manufacturing processes change.

Stay ahead of REACH SVHC updates

Get clarity before your next customer request or Candidate List update.

Whether you need supplier document review, article-level SVHC assessment, SCIP support, Annex XVII screening, or targeted testing, we can help you build a REACH process that fits your products and your markets.