REACH SVHC & SCIP Notification Requirements | EU Compliance

 


The ECHA REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) is one of the EU’s most significant frameworks for ensuring chemical safety. Two critical elements businesses must understand under REACH are obligations related to Substances of Very High Concern (SVHCs) and REACH SCIP notifications. Together, these requirements promote transparency around hazardous substances in products and support safer use, waste management, and circular economy objectives across the EU.

What Are Substances of Very High Concern (SVHCs)?

Substances of Very High Concern (SVHCs) are chemicals identified under REACH as posing serious risks to human health or the environment. These include carcinogenic, mutagenic, or reprotoxic substances (CMRs), as well as persistent, bioaccumulative, and toxic (PBT) or very persistent and very bioaccumulative (vPvB) substances. Once identified, SVHCs are added to the REACH Candidate List, which is regularly updated by the European Chemicals Agency (ECHA).

Inclusion on the Candidate List triggers specific communication and notification obligations for companies placing articles or substances containing SVHCs on the EU market. New additions to the list may also create new compliance deadlines for affected businesses.

SVHC Communication Obligations

Under Article 33 of REACH, suppliers must inform recipients in the supply chain if an article contains an SVHC at a concentration exceeding 0.1% weight by weight (w/w). This information must be sufficient to allow safe use of the article. Upon request, consumers must receive this information free of charge within 45 days.

In addition, under Article 7(2) of REACH, producers and importers may be required to notify ECHA if their articles contain Candidate List SVHCs above the 0.1% threshold and exceed specified annual quantity limits. This notification enables ECHA to monitor the presence of high-risk substances in the EU market.

The ECHA SCIP Database

Complementing REACH SVHC obligations is the SCIP database, established under the revised Waste Framework Directive (WFD). SCIP—Substances of Concern In articles as such or in complex objects (Products)—supports the EU’s transition to a circular economy by ensuring information on hazardous substances is available throughout a product’s lifecycle, including at the waste stage.

Since 5 January 2021, companies placing articles on the EU/EEA market that contain SVHCs above 0.1% w/w must submit notifications to the SCIP database. This requirement applies to articles on their own as well as components within complex products, with no minimum tonnage threshold.

Who Must Submit SCIP Notifications?

SCIP obligations apply to:

  • EU producers and importers of articles
  • Assemblers of complex products
  • Distributors and other entities placing articles on the EU market

SCIP notifications must include article identification details, SVHC information (including substance name and concentration range), and safe-use instructions. This data enables waste operators and consumers to manage products responsibly at end of life.

Why These Requirements Are Important

SVHC communication requirements under REACH and SCIP notification obligations together strengthen chemical transparency across supply chains. They provide critical safety information, encourage substitution of hazardous substances, and support circular economy goals by making essential data accessible to stakeholders.

Freyr’s regulatory experts assist companies manufacturing or supplying products to the EU by helping them understand SVHC obligations and achieve REACH SCIPcompliance. Meeting these requirements is essential to maintain chemical regulatory compliance, avoid penalties, protect brand reputation, and ensure continued access to the EU market.

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