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What is REACH SVHC? The 0.1% w/w per-article threshold and Article 33 communication duty, in plain English

REACH — Regulation (EC) 1907/2006 — requires anyone supplying an article in the EU that contains a Substance of Very High Concern above 0.1% w/w per article to (a) communicate sufficient information up the B2B chain under Article 33(1), (b) respond to consumer requests within 45 days under Article 33(2), and (c) notify the ECHA SCIP database. The Candidate List is updated by ECHA roughly each January and June — every update can pull new substances into your existing products.

7 MIN READ · UPDATED 7 JUNE 2026

Direct answer

REACH is the EU chemicals regulation. Three obligations attach to ecommerce sellers and brands placing physical products on the EU market:

  1. Article 33(1) — communicate sufficient information to B2B recipients (distributors, retailers) on any Substance of Very High Concern (SVHC) present above 0.1% by weight per article, including at minimum the substance name
  2. Article 33(2) — respond to a consumer request within 45 days, free of charge, with the same information
  3. SCIP — notify the ECHA SCIP database for every article containing an SVHC above the threshold; the notification is public

The Candidate List (the legal source of which substances are SVHCs) is updated by ECHA roughly each January and June. Every update can pull new substances into products that were compliant the day before.

What "per article" actually means

The 0.1% threshold applies to the individual article, not the finished product or the unit of sale. This is the O5 doctrine confirmed by the Court of Justice (Case C-106/14). A laptop is not one article — its keys, cables, batteries and screws are each separate articles, and the threshold is measured against each one. A 0.5g zipper pull containing more than 0.5mg of a Candidate-List substance triggers the obligation, even if the substance is trace-level in the garment as a whole.

This is what makes REACH a Bill-of-Materials problem, not a label problem.

The categories most exposed

  • Textiles — DMFu, lead, certain phthalates in coatings and prints
  • Electronics — flame retardants, lead solder, certain plasticisers in cables
  • Toys — phthalates, lead, cadmium (also Toy Safety Directive territory)
  • Footwear and leather goods — chromium VI, certain dyes
  • Cosmetics packaging and homeware — BPA, certain phthalates in soft plastics

The Candidate-List recheck pipeline

An article that was clean in June 2026 can be non-compliant in January 2027 because a substance in its BOM gets added to the Candidate List. Two operational duties follow:

  • Re-screen the existing catalogue every time ECHA publishes an update (twice a year)
  • Re-notify SCIP for any product that newly crosses the threshold

Missing the recheck is the most common REACH failure mode in ecommerce, because the article passed when it was first listed.

Why this sits on Pro and Agency only

REACH is genuinely a data-layer regulation: it requires per-component composition data and an automated recheck loop. Regonance ships it as a Pro and Agency module because of the BOM ingestion, the SCIP export, and the recheck pipeline against the ECHA Candidate-List updates — the volume of data and the recurring obligation do not fit a starter workflow.

What Regonance does on REACH/SVHC

  • Captures the Bill of Materials per product (article-level granularity)
  • Computes the 0.1% w/w per-article check against the current ECHA Candidate List
  • Generates the Article 33 B2B communication and the consumer 45-day response template
  • Produces a SCIP-compatible export for ECHA notification
  • Re-runs the assessment automatically on every Candidate List update — typically January and June — and flags products that newly cross the threshold

Frequently asked questions

What counts as an article under REACH?+

An object that has a specific shape, surface or design determining its function to a greater degree than its chemical composition. The CJEU confirmed in Case C-106/14 that the 0.1% threshold applies per individual article — not per finished product. A zipper, a battery, a cable, a button are each separate articles.

What is the 0.1% w/w threshold?+

0.1% by weight per article. If the substance accounts for more than 1mg in a 1g article, Article 33 applies. The threshold is measured against the article that contains the substance, not the unit of sale.

How quickly do I have to respond to a consumer SVHC request?+

Within 45 calendar days under Article 33(2), free of charge. The request can be sent by email or via your website contact form — there is no prescribed channel.

What is SCIP?+

The Substances of Concern In articles as such or in complex objects (Products) database, run by ECHA since 5 January 2021. You must notify SCIP for every article you place on the EU market that contains an SVHC above 0.1%. The notification is public.

How often does the SVHC Candidate List change?+

ECHA updates the Candidate List roughly twice a year — typically in January and June. Each update can pull substances into your existing catalogue, so re-screening on the published date is operationally required.

Is REACH available on every Regonance plan?+

REACH/SVHC is restricted to Pro and Agency. The module requires Bill-of-Materials data ingestion, SCIP export, and the automatic Candidate-List recheck pipeline — these are too data-heavy for the starter tiers.

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AI-assisted informational guidance. Not legal advice. Consult qualified counsel for your specific situation.