The ECHA REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a cornerstone of chemical safety legislation in the European Union. Two critical compliance areas under REACH are obligations related to Substances of Very High Concern (SVHCs) and REACH SCIP notifications. Together, these requirements enhance transparency regarding hazardous chemicals in products and promote safer use, disposal, and waste management across the EU.

What Are SVHCs?

Substances of Very High Concern (SVHCs) are chemicals identified under REACH as posing significant 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 maintained and regularly updated by the European Chemicals Agency (ECHA).

Inclusion on the Candidate List triggers specific communication and notification obligations for companies placing substances or articles containing SVHCs on the EU market. Newly added substances may also introduce new compliance deadlines for affected businesses.

SVHC Communication Requirements

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 ensure the safe use of the article. Upon request, consumers are entitled to 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 track significant volumes of high-risk substances placed on 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)—was introduced to support the EU’s transition to a circular economy by ensuring information on hazardous substances is available throughout a product’s entire lifecycle, including the waste phase.

Since 5 January 2021, companies placing articles on the EU/EEA market that contain SVHCs above 0.1% w/w are required to submit detailed notifications to the SCIP database. This obligation applies to standalone articles as well as components within complex products and is not subject to any minimum tonnage threshold.

Who Must Submit SCIP Notifications?

SCIP notification requirements apply to:

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

Notifications must include article identification details, SVHC information (including substance name and concentration range), and safe-use instructions. This information supports waste operators and consumers in managing products responsibly at end of life.

Why These Requirements Matter

SVHC communication obligations under REACH and SCIP notification requirements together strengthen chemical transparency across supply chains. They provide critical safety information, promote the substitution of hazardous substances, and support circular economy objectives by making essential data accessible throughout the product lifecycle.

Freyr’s regulatory experts support companies manufacturing or supplying products to the EU by helping them understand SVHC obligations and achieve REACH SCIP compliance. Meeting these requirements is essential to ensure regulatory compliance, avoid enforcement actions, protect brand reputation, and maintain uninterrupted access to the EU market.