The SVHC Candidate List identifies substances of concern and triggers a duty to communicate. The SCIP database is where you report products containing those substances. REACH Annex XVII restricts or bans the use of specific substances outright. They are three distinct regulatory mechanisms under the same REACH umbrella, each with different triggers, obligations, and consequences.
Three mechanisms, one regulation
All three originate from REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), the EU's comprehensive chemical regulation (EC No 1907/2006). But they serve different functions and create different obligations. Confusing them, which happens frequently in product data management, leads to compliance gaps and unnecessary work.
| Mechanism | What it does | Legal basis | Managed by |
|---|---|---|---|
| SVHC Candidate List | Identifies substances of very high concern | REACH Article 59 | ECHA |
| SCIP database | Collects data on articles containing SVHCs | Waste Framework Directive Article 9(1)(i) | ECHA |
| REACH Annex XVII | Restricts or bans substances in products | REACH Article 67-73 | European Commission |
The SVHC Candidate List: identification and communication
The Candidate List is the starting point. When ECHA identifies a substance as an SVHC and places it on the Candidate List, two obligations activate immediately:
-
Article 33 communication. Suppliers of articles containing the substance above 0.1% w/w must inform their customers (automatically for B2B, on request for consumers).
-
Article 7(2) notification. Importers and producers of articles must notify ECHA if the substance is present above 0.1% w/w and the total quantity of the substance in those articles exceeds 1 tonne per year per company.
The Candidate List does not restrict use. A product containing a Candidate List substance is perfectly legal to sell. The obligation is to communicate, not to eliminate.
What it means for product data
You need a field in your product data that indicates whether each product contains any Candidate List substance above 0.1% w/w. If yes, which substance(s), their CAS numbers, and a safe use statement. This information must be passed to every recipient in the supply chain.
The SCIP database: reporting for waste management
SCIP (Substances of Concern In articles as such or in complex objects/Products) is a database operated by ECHA under the Waste Framework Directive, not directly under REACH. It has been mandatory since January 5, 2021.
Who must notify
Any company that places an article on the EU market that contains a Candidate List substance above 0.1% w/w must submit a SCIP notification. This includes:
- EU manufacturers
- EU importers
- EU distributors who supply articles under their own brand
- Any company that assembles articles into complex products
What the notification contains
A SCIP notification includes:
| Data element | Description |
|---|---|
| Article identity | Name, primary article identifier (EAN, internal reference) |
| Substance identity | CAS number, EC number, substance name |
| Concentration range | The range within which the substance is present |
| Article category | TARIC code or free text description |
| Safe use instructions | How to use the article safely given the substance presence |
| Material/mixture category | What part of the article contains the substance |
How SCIP differs from Article 33
Article 33 is a supply chain communication requirement. You tell your customer. SCIP is a database notification requirement. You tell ECHA. The data content overlaps, but the mechanism and audience differ.
Article 33 is triggered by each individual sale. SCIP is a one-time notification per article (updated if the Candidate List changes and new substances apply).
What it means for product data
Your PIM should store SCIP notification references (simplified SCIP numbers or dossier UUIDs) for products that have been notified. When the Candidate List is updated, you need to check whether existing products now require a new SCIP notification due to newly listed substances.
REACH Annex XVII: restrictions that bite
Annex XVII is fundamentally different from the Candidate List and SCIP. While the Candidate List creates communication obligations and SCIP creates reporting obligations, Annex XVII creates hard restrictions. A substance restricted under Annex XVII cannot be used in the specified manner, period.
How restrictions work
Each entry in Annex XVII specifies:
- The substance or substance group being restricted.
- The conditions of restriction. This can range from "shall not be placed on the market in articles above X concentration" to "shall not be used in [specific application]."
- Any exemptions. Many restrictions have carve-outs for specific industries, historical uses, or technical necessities.
Restrictions relevant to electrical products
| Annex XVII Entry | Substance | Restriction | Relevance to electrical |
|---|---|---|---|
| Entry 23 | Cadmium | Max 0.01% in plastic and paint | Cable insulation pigments |
| Entry 27 | Nickel | Max release rate from articles in contact with skin | Nickel-plated connectors and fittings |
| Entry 47 | Chromium VI | Max 3 mg/kg in leather | Work gloves used with electrical products |
| Entry 51 | Phthalates (DEHP, DBP, BBP, DIBP) | Max 0.1% individually in plasticized materials in articles | PVC cable insulation and conduit |
| Entry 63 | Lead | Max 0.05% in articles placed on the market for supply to the general public | Lead in solder, brass fittings |
| Entry 72 | Substances in tattoo ink | Not relevant | Not relevant |
| Entry 75 | Microplastics | Restrictions on intentionally added microplastics | Some cleaning products used in electrical maintenance |
The RoHS overlap
For electrical products, there is significant overlap between REACH Annex XVII restrictions and the RoHS Directive (2011/65/EU). Both restrict lead, cadmium, mercury, and hexavalent chromium. The thresholds and scope differ:
- RoHS restricts these substances specifically in electrical and electronic equipment (EEE) at the homogeneous material level.
- REACH Annex XVII restrictions apply to all articles, not just EEE, with different concentration thresholds and different definitions of "article."
Products must comply with both. It is not sufficient to check only RoHS or only REACH.
What it means for product data
Annex XVII compliance is a binary pass/fail. Either the product meets the restriction conditions or it does not. If it does not, the product cannot be legally sold in the EU for the restricted application. There is no "communicate and sell anyway" option as there is with the SVHC Candidate List.
Your product data should include a compliance declaration confirming that applicable Annex XVII restrictions are met.
How the three mechanisms interact
Consider a common scenario: DEHP (bis(2-ethylhexyl) phthalate, CAS 117-81-7) in PVC cable insulation.
| Mechanism | Status | Obligation |
|---|---|---|
| SVHC Candidate List | Listed since 2008 | Inform customers if DEHP >0.1% w/w in cable |
| SCIP database | Notification required | Submit SCIP notification for cables with DEHP >0.1% w/w |
| REACH Annex XVII (Entry 51) | Restricted since July 2020 | DEHP shall not be used >0.1% in plasticized material in articles supplied to the general public |
| Authorization List (Annex XIV) | Listed, sunset date passed | Manufacturers must have authorization to use DEHP |
A single substance can trigger all three mechanisms simultaneously. This is why compliance data management requires tracking substance identity (by CAS number), presence thresholds, and the regulatory status under each mechanism independently.
Practical implications for product data teams
Build three separate compliance flags
svhc_present: true/false (+ substance list if true)
scip_notified: true/false (+ SCIP reference if true)
annex_xvii_compliant: true/false (+ declaration reference)
These are independent. A product can be SVHC-positive (contains a Candidate List substance), SCIP-notified, and Annex XVII compliant (the substance is present but below the restriction threshold or an exemption applies).
Monitor updates to all three lists
- Candidate List: Updated approximately twice per year (January and July).
- SCIP database: Notifications required whenever the Candidate List is updated and new substances are relevant.
- Annex XVII: Amended by Commission regulations, typically 1-3 new or modified entries per year.
Cross-reference your substance data against all three lists when updates occur. Use the free SVHC checker to verify individual substance status against the current Candidate List.
Centralize substance data
The foundation for all three compliance mechanisms is knowing what substances are in your products and at what concentrations. This data comes from suppliers via material declarations, SDS documents, and compliance certificates. Store CAS numbers as the primary key for substance identification. Validate them with the CAS number validator to catch transcription errors before they propagate into compliance records.