# REACH SVHC Importer Obligations: What to Check and Declare
REACH is the EU's chemicals regulation, and its SVHC provisions, covering Substances of Very High Concern, create direct duties for importers of physical products. Unlike RoHS, which bans substances above limits in electronics, the SVHC regime is built on information and notification: know what is in your products, tell your customers, and tell the authorities when thresholds are crossed. These REACH SVHC importer obligations apply to importers of all kinds of goods from China, not just chemicals or electronics. If you place products on the EU market, this guide tells you what to check and what to declare.
REACH as a whole is enormous, covering registration of chemical substances, evaluation, authorization, and restriction. Importers of articles, meaning physical products like textiles, furniture, toys, and electronics, face three parts under the REACH SVHC importer obligations umbrella: the SVHC communication and notification duties, the authorization requirements for substances on the Authorisation List, and the restrictions in the regulation's annex on restricted substances. This guide focuses on SVHC, with the other two covered where they touch the importer's daily work.
The core idea is simple and far-reaching. The EU maintains a Candidate List of substances identified as being of very high concern: carcinogens, mutagens, reproductive toxicants, persistent and bioaccumulative substances, and substances of equivalent concern such as endocrine disruptors. The list grows over time as new substances are assessed and added. Importers must know whether their products contain these substances above the threshold, and act accordingly. The list is the moving part. Your process for watching it is the compliance.
REACH SVHC importer obligations: the Candidate List and the threshold
The Candidate List is published and updated by the European Chemicals Agency, ECHA. Each update can add substances, and the list has grown steadily since its creation. The REACH SVHC importer obligations in this guide all key off this list, which means the first operational duty is list monitoring. Assign responsibility for checking Candidate List updates, because the REACH SVHC importer obligations move every time the list does. Define what happens inside your company when a new substance is added: which products get screened, who asks the suppliers, and on what timeline.
The threshold that triggers duties is 0.1 percent weight by weight in the article. The interpretation of "article" here went through years of legal debate and was settled by the European Court of Justice: the threshold applies to each article in a complex product, not to the product as a whole. A screw, a plastic housing, and a textile strap inside one product are each assessed separately against the 0.1 percent threshold.
This interpretation, sometimes called "once an article, always an article," has major practical consequences. You cannot dilute a substance below the threshold by embedding a small component in a large product. Each component must be evaluated on its own. For importers, this means SVHC screening must reach the component level, which means supplier data at the component level. A finished-product test alone cannot reliably map SVHC content across every component of a complex product.
The threshold is about concentration, not about total quantity or about risk in use. A substance present above 0.1 percent in a component triggers the communication duty even if exposure during normal use is minimal. The regulation's logic is information: downstream users and consumers have a right to know, and the supply chain needs the data to manage substances over time.
Duty one: communicate down the supply chain
When an article contains a Candidate List substance above 0.1 percent, the REACH SVHC importer obligations require the supplier of the article to provide the recipient with enough information for safe use, including at minimum the name of the substance. For professional customers, this information must be provided automatically. For consumers, it must be provided on request, within a defined response time.
For the importer, this means two capabilities. First, you must know the SVHC content of your products at the component level, which requires supplier declarations and testing as described below. Second, you must have a process for answering customer and consumer inquiries with accurate substance information. A consumer who asks about SVHC in your product is exercising a legal right, and the answer must be correct and timely.
Build the communication into your product information systems. Maintain SVHC data by product and component, linked to the Candidate List version it was assessed against. When the list updates, the data needs re-screening. Importers who keep this in a spreadsheet per product find updates painful. Importers who keep it in a structured system find them routine. The regulation does not mandate a system, but the workload mandates one in practice.
Safety information should be practical. Telling a customer that a substance is present is the minimum. Explaining where it is in the product and how to handle the product safely is the spirit of the duty. For most consumer products, normal use guidance plus disposal information covers it.
Duty two: notify ECHA through the SCIP database
Beyond communicating to customers, importers and other article suppliers must notify ECHA when their articles contain Candidate List substances above 0.1 percent, through the SCIP database. SCIP stands for Substances of Concern In articles, as such or in complex objects (Products), and it was created under the Waste Framework Directive to give waste operators and regulators visibility into hazardous substances in products.
The notification duty under the REACH SVHC importer obligations applies to articles placed on the EU market. The importer, as the first EU operator for goods from China, generally carries this duty. Notifications include identification of the article, the SVHC it contains, concentration range, material and mixture categories, and safe use information. ECHA publishes much of this data, which means your notifications become public information about your products' substance content. Accuracy matters twice: for compliance and for reputation.
SCIP notification is an ongoing duty, not a one-time filing. New products need notifications. Changed products need updated notifications. Candidate List updates can trigger new notifications for existing products. Build SCIP into the product launch checklist alongside labeling and documentation, and assign ownership for keeping notifications current.
The practical burden is real, especially for importers with large catalogs of complex products. Each notifiable article needs its data assembled and submitted. Service providers and software tools exist for SCIP submissions, and many importers outsource the mechanics while retaining responsibility for the data's accuracy. Whatever the mechanics, the importer remains the duty holder.
Duty three: watch authorization and restriction
SVHC status is often a step toward stricter control. Substances move from the Candidate List to the Authorisation List, which means they cannot be used after a sunset date unless an authorization has been granted for the specific use. Importers of articles containing an Authorisation List substance need to know whether the use in their product is covered by an authorization. An article containing a substance whose authorization has expired for that use cannot be placed on the market.
Separately, the regulation's restrictions annex can ban or limit substances in specific product types outright. Restrictions apply to importers directly: a restricted substance in your product above the restricted limit makes the product noncompliant regardless of SVHC communication. Lead in jewelry, certain phthalates in toys and childcare articles, and azo dyes in textiles are long-standing examples of restrictions that hit importers of Chinese goods.
The REACH SVHC importer obligations discipline is to track all three layers for the substances in your products: Candidate List for communication and SCIP, Authorisation List for use permissions, restrictions for outright limits. A substance can sit on all three lists with different implications at each layer. Your supplier declarations should capture full substance content so you can screen against all three, not just the Candidate List.
How importers actually check: declarations and testing
Knowing SVHC content at the component level requires a supply chain data program, and the REACH SVHC importer obligations make it non-optional. The foundation is supplier declarations: require factories to declare the SVHC content of the materials and components they supply, against the current Candidate List, with each update. Standard declaration formats exist, and many suppliers serving the EU market already produce them.
Declarations have limits. Suppliers may not know their own sub-suppliers' chemistry, declarations go stale as the Candidate List grows, and some suppliers sign declarations without checking. Layer risk-based testing on top: test high-risk materials and components for the SVHC most likely to be present in your product types. Phthalates in flexible plastics, flame retardants in electronics housings, azo-releasing dyes in textiles, and heavy metals in metal and leather goods are the usual suspects by category.
Testing for SVHC is broader and more expensive than testing for a fixed list like RoHS, because the Candidate List keeps growing and covers diverse chemistries. No single test covers all SVHC. Work with your lab on a screening strategy for your product types: which substances to test for, in which materials, and how often. Full Candidate List screening of every component of every product is usually impractical. Targeted screening based on material risk is the professional standard.
Change control closes the loop. Material substitutions, new sub-suppliers, and cost-down redesigns can introduce SVHC that was never there before. Supplier agreements should require notification of material changes, and your program should define which changes trigger re-screening. The REACH SVHC importer obligations are continuous because the products and the list are always moving.
Conclusion
The REACH SVHC importer obligations reduce to a cycle: monitor the Candidate List, know your products' substance content at the component level through declarations and risk-based testing, communicate substance information to customers and consumers, notify ECHA through SCIP, and watch the Authorisation List and restrictions for harder limits. Build each step into standing processes: list monitoring with an owner, supplier declarations as a contract term, SCIP notification in the product launch checklist, and change control on materials. The Candidate List will keep growing, and importers with a working data pipeline will absorb each update as routine. Importers without one will discover each update as a crisis. Check current official sources for the list and duties in force today, and treat substance knowledge as a core sourcing competence rather than a regulatory afterthought. That is the REACH SVHC importer obligations mindset that survives list updates: process, not panic.
FAQ
### What is an SVHC?
A Substance of Very High Concern: a substance identified for properties like carcinogenicity, mutagenicity, reproductive toxicity, persistence and bioaccumulation, or equivalent concern such as endocrine disruption. ECHA publishes them on the Candidate List, which grows over time.
### Does the 0.1 percent threshold apply to the whole product or each component?
Each article within a complex product, following the European Court of Justice interpretation. A component containing an SVHC above 0.1 percent triggers duties even if the substance is a tiny fraction of the finished product's total weight.
### What is the SCIP database?
ECHA's database for notifications about Candidate List substances in articles, created to inform waste operators, regulators, and consumers. Importers placing notifiable articles on the EU market must submit SCIP notifications with substance and safe-use data.
### Do I need to test every product for every SVHC?
In practice, no. The professional approach combines supplier declarations against the current Candidate List with risk-based testing of high-risk materials for the SVHC likely in your product types. Full screening of everything is usually impractical; targeted screening plus change control is the standard.
### What happens when a substance moves from the Candidate List to the Authorisation List?
After the sunset date, the substance cannot be used without an authorization covering that use. Importers must check whether their product's use is authorized. Articles containing the substance for an unauthorized use cannot be placed on the market.
### How is REACH SVHC different from RoHS?
RoHS bans ten specific substances above limits in electrical and electronic equipment. REACH SVHC covers a growing list of substances across all product types, with duties centered on communication and notification at 0.1 percent per article, plus authorization and restriction layers. Many electronic products must satisfy both.
### What is the first step to meet REACH SVHC importer obligations?
Set up Candidate List monitoring with a named owner. The REACH SVHC importer obligations all key off the list, so watching it is the foundation everything else builds on.
### Do REACH SVHC importer obligations apply to packaging?
Packaging placed on the market is itself an article in many cases, so the REACH SVHC importer obligations can apply to it. Assess packaging alongside the product rather than forgetting it.
### How do REACH SVHC importer obligations interact with customer contracts?
Many B2B customers require SVHC declarations as a contract term. Meeting the REACH SVHC importer obligations with organized data makes those declarations routine instead of a fire drill.