What is the SVHC Candidate List? REACH Compliance for Product Data

What SVHC stands for

SVHC means Substance of Very High Concern. The term comes from Article 57 of the EU REACH regulation (EC No 1907/2006), which defines the criteria for a substance to be identified as an SVHC:

1. Carcinogenic, mutagenic, or toxic for reproduction (CMR). Category 1A or 1B substances under CLP regulation. Example: lead compounds (CAS 7439-92-1).

2. Persistent, bioaccumulative, and toxic (PBT). Substances that do not break down in the environment, accumulate in living organisms, and are toxic. Example: certain brominated flame retardants.

3. Very persistent and very bioaccumulative (vPvB). Even more stringent than PBT. Substances that persist in the environment for very long periods and accumulate significantly.

4. Equivalent level of concern. Substances with scientific evidence of probable serious effects to human health or the environment, even if they do not fit the CMR/PBT/vPvB categories. Example: endocrine disruptors like bisphenol A (CAS 80-05-7).

The Candidate List process

How substances are added

Any EU Member State or ECHA (at the request of the European Commission) can propose a substance for identification as an SVHC. The process follows these steps:

1. Dossier preparation. The proposing authority prepares an Annex XV dossier documenting why the substance meets SVHC criteria.

2. Public consultation. ECHA publishes the proposal and invites comments from industry, NGOs, and other stakeholders for 45 days.

3. Member State Committee. If there are comments, the ECHA Member State Committee discusses the proposal and seeks unanimous agreement. If unanimous agreement is reached, the substance is added to the Candidate List.

4. Publication. ECHA updates the Candidate List on its website, typically twice per year (January and July).

Update cycle

The Candidate List grows with each update. Since the first publication in October 2008 (15 substances), the list has grown to over 240 entries by early 2026. ECHA's stated goal is to have all relevant SVHCs identified by 2027.

Each update adds between 2 and 12 new substances. There is no mechanism to remove substances from the Candidate List (short of the substance being de-identified, which has never happened in practice). The list only grows.

Article 33: The duty to communicate

Article 33 of REACH creates two obligations for suppliers of articles (products):

Obligation to professional recipients

Any supplier of an article that contains a Candidate List substance above 0.1% weight by weight (w/w) must provide the recipient with sufficient information to allow safe use of the article. At a minimum, this means providing the name of the substance. This information must be provided automatically, without being asked.

Obligation to consumers

Upon request, any supplier must provide this same information to a consumer within 45 days of the request, free of charge.

What "0.1% by weight" means

The 0.1% threshold applies to the article as produced or imported, not to individual components. However, a 2015 Court of Justice of the EU ruling (C-106/14) clarified that the threshold applies to each individual article within a complex product. A luminaire containing a PCB with lead solder above 0.1% of the PCB's weight triggers Article 33, even if lead is below 0.1% of the complete luminaire's weight.

This ruling significantly expanded the scope of Article 33 for electrical product manufacturers and importers.

SVHCs commonly found in electrical products

What this means for product data

Data requirements

For every product in your catalog, you need to know:

1. Does it contain any Candidate List substance above 0.1% w/w?
2. If yes, which substance(s)?
3. What is the concentration range?

This data typically comes from the manufacturer in the form of SVHC declarations, SCIP notifications, or material composition statements.

The SCIP database

Since January 2021, EU importers and producers must submit notifications to ECHA's SCIP (Substances of Concern In articles as such or in complex objects/Products) database for any article containing a Candidate List substance above 0.1% w/w. The SCIP notification includes the article identifier, the substance identity (by CAS and EC number), concentration range, and safe use instructions.

For distributors, this means suppliers should be able to provide SCIP notification references for products that contain SVHCs.

Keeping up with updates

Because the Candidate List grows twice per year, compliance is not a one-time exercise. A product that was SVHC-free in 2024 might contain a newly listed substance in 2025. Product data teams need a process to:

1. Monitor Candidate List updates (ECHA publishes them on its website).
2. Cross-reference new additions against their product portfolio's material compositions.
3. Update product compliance data and customer communications.
4. Ensure new SCIP notifications are submitted if required.

Check your products' substances against the current Candidate List using the free SVHC checker. It cross-references CAS numbers against the latest ECHA Candidate List entries.

The Candidate List vs the Authorization List

The Candidate List is often confused with the Authorization List (REACH Annex XIV). They are different:

• Candidate List: All identified SVHCs. Triggers Article 33 communication duties and SCIP notification. No restriction on use.
• Authorization List (Annex XIV): A subset of Candidate List substances that require authorization for continued use after a sunset date. Companies must apply for and receive authorization from the European Commission to continue using these substances.

A substance moves from the Candidate List to the Authorization List through a separate recommendation and decision process. Not all Candidate List substances end up on the Authorization List.

Practical steps for electrical distributors

1. Request SVHC declarations from all suppliers. Standard practice is a declaration per product or product family stating whether Candidate List substances are present above 0.1% w/w.

2. Store SVHC data in your PIM. At minimum: a boolean field (contains SVHC yes/no), and if yes, the substance name(s) and CAS number(s).

3. Automate Candidate List cross-referencing. When the list is updated, check your substance database against the new entries. Use the SVHC checker to validate individual CAS numbers.

4. Communicate proactively. Do not wait for customers to ask. Include SVHC information in product data sheets and make it available on your webshop.

5. Track SCIP notifications. For products you import directly into the EU, ensure SCIP notifications are filed and the reference numbers are stored in your product data.