EU / Chemicals & Materials
A product can pass every REACH check at launch and still fall out of compliance months later with nothing about the product changing — because the Candidate List of Substances of Very High Concern keeps growing. It reached 253 entries with the 4 February 2026 update, and each listing opens its own 6-month notification window for articles that cross the 0.1% threshold.
Last updated 11 September 2026
CE marking, RED, RoHS — most of the obligations our ICP is used to are things you check once against a fixed standard and move on. REACH SVHC doesn't work that way: ECHA adds new substances to the Candidate List on a rolling basis, several times a year, based on ongoing hazard assessment. A component or material that was clean at the time of a product's last compliance review can become an SVHC-containing article the moment ECHA lists a substance it contains — with zero change to the bill of materials. That means SVHC compliance is a monitoring process, not a checkbox, and it's the one common EU obligation in our ICP's list that keeps generating new deadlines indefinitely rather than a single date to hit.
Source: ECHA, Candidate List of substances of very high concern for authorisation.
On 4 February 2026, ECHA added n-hexane and Bisphenol AF (BPAF), taking the Candidate List to 253 entries. n-hexane is a widely used solvent for degreasing and flux-residue removal in electronics manufacturing; BPAF is used as a process regulator in polymer production and as a cross-linking agent for certain fluoroelastomers, and has been identified as a PFAS. Each of those substances runs its own independent 6-month notification clock from its listing date, and so will every future addition.
Sources: Certivo, "ECHA Adds Two Chemicals to SVHC Candidate List"; SGS, "ECHA Expands Candidate List to 253 SVHCs".
Two separate duties key off the same 0.1% weight-by-weight threshold, and it's easy to conflate them. First: if any SVHC is present in an article above 0.1% w/w, the supplier must give recipients — and consumers, on request within 45 days — enough information for safe use. This duty applies regardless of how much of the article is placed on the market; even a single unit triggers it. Second: if that same threshold is crossed and the SVHC is present in the producer's or importer's articles in quantities totalling more than 1 tonne per year, REACH Article 7(2) requires a formal notification to ECHA, due within 6 months of the substance's Candidate List entry — so for the 4 February 2026 additions, that notification window closed 4 August 2026.
Source: ECHA, SVHC in articles.
SCIP notification is often confused with the Article 7(2) duty above, but it's a distinct requirement under the EU Waste Framework Directive, not REACH itself. SCIP is triggered purely by an article containing an SVHC above 0.1% w/w — there's no 1-tonne threshold, so it catches many more producers than the REACH notification duty does. For the substances added 4 February 2026, the SCIP notification deadline landed 4 August 2026, the same six-month structure as the REACH clock, but a separate filing to a separate database.
Source: Space Wiki, "REACH SVHC 2026: Candidate List, SCIP & Notification Duties".
REACH enforcement sits with individual EU member states, so penalties vary by country — but the exposure is real: administrative fines for registration or authorisation infringements, criminal penalties for serious cases that can run into the millions of euros, product recalls, and being blocked from placing goods on the EU market pending a fix. The more common failure isn't a single missed filing — it's not having a live process to catch a Candidate List update at all, so a product quietly drifts out of compliance and nobody notices until a customs check, a customer's supply-chain audit, or an incident brings it to light.
SVHC (Substance of Very High Concern) is a status ECHA assigns to chemicals under the EU REACH Regulation because of carcinogenic, reproductive-toxic, PBT, or equivalent-concern properties. Unlike a one-off certification, the Candidate List is updated several times a year — it reached 253 entries with the 4 February 2026 update — so a product that was compliant at launch can fall out of compliance the moment a substance it contains gets listed, with no change to the product itself.
If any SVHC is present in an article above 0.1% weight by weight, the supplier must give recipients (and consumers, on request, within 45 days) enough information for safe use — this duty applies regardless of quantity. Separately, if the same 0.1% w/w threshold is crossed AND that SVHC is present in the producer's or importer's articles in quantities totalling more than 1 tonne per year, they must notify ECHA under REACH Article 7(2), within 6 months of the substance's Candidate List entry.
ECHA added n-hexane and Bisphenol AF (BPAF) on 4 February 2026, taking the list to 253 entries — n-hexane is a common degreasing/flux-cleaning solvent in electronics manufacturing, and BPAF is used in polymer processing and fluoroelastomer cross-linking.
No — they're related but separate duties. REACH Article 7(2) notification to ECHA is a REACH obligation tied to quantity (over 1 tonne/year of the SVHC across all your articles containing it above 0.1%) and article placement on the market. SCIP notification is a duty under the EU Waste Framework Directive, triggered purely by an article containing an SVHC above 0.1% w/w regardless of quantity, so it catches many more producers. For substances added 4 February 2026, the SCIP notification deadline fell 4 August 2026 — six months out, same clock structure as the Article 7(2) deadline.
Enforcement is set at EU member-state level, so penalties vary by country, but REACH infringements carry real exposure: fines that in some jurisdictions reach into the millions of euros for serious cases, plus product recalls and being blocked from the EU market pending compliance. The more common failure mode isn't a single missed deadline — it's not having a live process to catch a Candidate List update at all, so a compliant product quietly becomes non-compliant and nobody notices until an inspection or a customer's own supply-chain audit flags it.
SVHC monitoring is the one obligation on this list that never actually finishes — every Candidate List update starts the clock again on your bill of materials. We build the recurring check into the same market-access engagement as CE/UKCA marking and RoHS, so a new listing gets caught against your actual component list before the notification window closes, rather than surfacing as a surprise during a customer audit.
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