Under REACH Regulation (EC) No 1907/2006, Article 33(2), if any relevant article contains a Candidate List SVHC above 0.1% w/w, you must reply free of charge within 45 days. If the threshold is not met, Article 33(2) does not apply, but ECHA recommends replying to confirm this. We will display this information to consumers researching your product, and this also ensures we do not send you follow-up queries.

An SVHC is a “Substance of Very High Concern” (REACH Article 57). ECHA publishes SVHCs in its Candidate List, which is updated as new substances are added.

Yes, if you supply an article or a complex object.

An article is an object whose shape, surface, or design mainly determines its function. When several articles are assembled into a larger product, the assembled product is a complex object and the component parts still count as individual articles as long as they keep their defining form and function. Both the assembled product and component articles should be checked when replying to Article 33(2) requests. If any component article contains an SVHC above 0.1% w/w, you must disclose it to the consumer on request.

Packaging often qualifies as its own article, so assess it separately.

No, Article 33(2) is an article obligation, so it does not apply if your product is a substance or mixture, meaning its chemical composition determines its function as much as, or more than, its shape, surface, or design.

The exception is where the product also includes an article or complex object element. If the substance or mixture is physically separable, Article 33(2) can apply to the surrounding object if a relevant part contains a Candidate List SVHC above 0.1% w/w, but it does not apply to the separable substance or mixture. If the substance or mixture is integral, treat the product as an article or complex object, meaning Article 33(2) applies where a relevant part contains a Candidate List SVHC above 0.1% w/w.

This typically arises in relation to packaging. Even if what you sell is a substance or mixture, the packaging can be an article or complex object under REACH, and if any packaging article contains a Candidate List SVHC above 0.1% w/w, you must provide that information to a consumer on request.

The regulation applies to the supplier of an article, meaning anyone who supplies the article in the EU/EEA supply chain. This can include the manufacturers/assemblers, importers, distributors/wholesalers, retailers, and online sellers-of-record. If a marketplace only hosts listings and another business is the seller, the seller (not the platform) is usually the supplier.

To calculate % w/w, divide the weight of the SVHC in the article by the total weight of the article, then multiply by 100. For complex objects, assess each component article against 0.1% w/w, since small parts can exceed the threshold even if the whole product does not.

If the SVHC is in a joining material (such as adhesive or solder) or a coating, use the weight of the joined or coated complex object as the denominator, instead of assessing each component article separately.

It must name any Candidate List SVHC above 0.1% w/w in a relevant article or complex object, and state that it appears on the most recent Candidate List update, which is why you are providing the information.

You must also include any safe use information available to you, with enough detail for normal and reasonably foreseeable use. Where relevant, cover the product lifecycle, including storage, installation, use, cleaning and maintenance, repair, damage or wear, end of life steps such as recycling or disposal, and foreseeable misuse that could increase exposure.

If your upstream supplier is EU or EEA based and supplies an article containing a Candidate List SVHC above 0.1% w/w, they have an obligation to provide sufficient safe use information to business recipients, including at minimum the substance name, so you should request it and document the request. You still remain responsible for replying to the consumer within 45 days using the information available to you and you should avoid a bare “we don’t know” response. Explain what checks you have performed, what you have asked your supplier for, and when you will follow up if new information emerges.

You should respond within the deadline with the information currently available to you, and document the steps you are taking to obtain missing SVHC information from your upstream suppliers. Avoid a bare “we don’t know” response; explain what checks you have performed and when you will follow up if new information emerges.

REACH is enforced by national inspectorates and other authorities in each Member State; your national REACH helpdesk can direct you to the right body. 

Not replying or replying incorrectly may be treated as non-compliance and can trigger enforcement. Penalties vary by Member State and may include compliance orders, administrative fines, and stronger sanctions for serious or repeated breaches. Base your response on reliable evidence such as supplier declarations, product specifications, and test results where needed and correct any errors promptly.