On 4 February 2026, ECHA added n-hexane and bisphenol AF to the REACH Candidate List, bringing it to 253 entries. That single action started a six-month clock. For any producer or importer of articles that contain either substance above threshold in relevant volumes, the REACH Article 7(2) notification deadline is 4 August 2026. This guide explains who must file, how the thresholds actually work, and what a defensible filing process looks like.

If you want to check your current exposure before the clock runs out, you can book a compliance risk assessment to map which articles in your portfolio touch the new listings.

Key Takeaways

• 📌 The SVHC Candidate List now stands at 253 entries after n-hexane and bisphenol AF were added on 4 February 2026.

• ⏳ The REACH Article 7(2) notification deadline for these two substances is 4 August 2026, six months from inclusion.

• ⚠️ Article 7(2) has a dual trigger: above 0.1% w/w in the article and more than one tonne per year of the substance across those articles. The 0.1% threshold alone triggers Article 33, not Article 7(2).

• 📄 Article 33 communication duties apply immediately, with a 45-day response window to consumer requests, and are criminally enforceable in several EU states.

• 🔗 The 0.1% w/w calculation is per article under the "once an article, always an article" principle, which pushes the obligation deep into complex assemblies and the supply chain.

• 🤖 Screening 253 entries against a live BOM is not a manual task at scale, which is where BOM-level compliance intelligence and automated supplier data collection become operational necessities.

Executive Regulatory Overview

The REACH Candidate List is ECHA's register of Substances of Very High Concern (SVHCs) under Regulation (EC) No 1907/2006. Inclusion does not ban a substance. It activates a defined set of legal obligations that flow to manufacturers, importers, and suppliers of substances, mixtures, and articles across the EU and EEA.

The February 2026 update is significant beyond the headline count. n-Hexane is the first substance added on the basis of neurotoxicity as an equivalent level of concern under Article 57(f), rather than the traditional carcinogenic, mutagenic, or reprotoxic route. That signals a widening basis for future listings, which is why treating each update as a one-off is a weak posture. You can review the specifics of the two new entries in our breakdown of the ECHA February 2026 SVHC additions.

REACH Article 7(2) notification deadline timeline from February to August 2026

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Framework Scope: The Candidate List and Its Obligations

Candidate List inclusion triggers four distinct obligations, and they are frequently confused. Keeping them separate is the foundation of an accurate compliance response. Our REACH framework page sets out the wider regime, but the obligations tied specifically to this listing are summarized below.

The distinction between the 0.1% threshold and the added one-tonne threshold is the single most misunderstood point, and it drives the next section. Structured BOM substance and threshold management is what keeps these four obligations from being mixed up in practice.

Article 7(2): The Real Trigger and the Common Mistake

Article 7(2) requires a producer or importer of articles to notify ECHA when both conditions are met:

1. The SVHC is present in those articles above a concentration of 0.1% w/w, and

2. The total quantity of that SVHC present in those articles exceeds one tonne per producer or importer per year.

Notification is not required where exposure to humans and the environment can be excluded during normal and reasonably foreseeable conditions of use, including disposal, or where the substance has already been registered for that use. This is confirmed directly by ECHA's summary of Candidate List obligations.

The practical consequence is that a small number of high-volume article lines can create an Article 7(2) duty, while many low-volume lines may only carry the Article 33 communication duty. Getting this wrong in either direction is costly: over-notifying wastes engineering time, under-notifying creates enforcement exposure. Accurate BOM-level compliance tracking is what separates a defensible filing from a guess.

REACH Article 7(2) notification versus Article 33 SVHC trigger thresholds comparison

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Article 33 and SDS: The Communication Duties That Run in Parallel

Article 33 applies from the moment a substance is listed, with no one-tonne threshold. Under Article 33(1), any supplier of an article containing an SVHC above 0.1% w/w must pass safe-use information down the chain. Under Article 33(2), a supplier must respond to a consumer request within 45 days, free of charge.

Suppliers of substances and mixtures must also update the relevant Safety Data Sheet, including Section 15, to reflect SVHC identification under Article 31(9)(a). These duties do not wait for the August notification date, which is why chemical and hazmat compliance workflows need to activate the day a listing is published. Managing the request-and-response cycle at volume typically depends on customer trust centers and self-service reporting rather than ad hoc email.

The 0.1% w/w Calculation Methodology

The 0.1% threshold is calculated per article, not across the finished complex product. This follows the "once an article, always an article" (O5A) principle established by the Court of Justice ruling in Case C-106/14. A screw, a connector, or a coated component retains its status as an article inside a larger assembly, so the concentration is assessed at that component level.

For a $10B manufacturer with multi-tier suppliers, this is the hard part. You cannot answer the 0.1% question without full-material-disclosure-grade data on every article in the assembly. This is a multi-tier supply chain transparency problem before it is a filing problem, and our guide to automating SVHC compliance walks through the data model in detail.

Affected Industries and Product Categories

The February additions reach further than they first appear because both substances sit in common processing and material chemistries.

🏭 Electronics and electrical equipment: n-hexane appears in flux-residue cleaning of PCBs and adhesives; BPAF appears in epoxy resins and high-performance plastics. See our electronics manufacturing view.

🏭 Automotive and industrial: BPAF is used in fluoroelastomers, crosslinking, and specialty polymers common in automotive manufacturing supply chains.

🏭 Coatings, adhesives, and cleaning: n-hexane is a widespread solvent across formulation and degreasing processes.

Because Candidate List entries can be group entries, the number of affected chemicals is higher than the entry count suggests, which is a recurring theme in our coverage of recent SVHC and Annex XVII changes.

Reporting, Documentation, and Audit Challenges

The August deadline is a documentation problem more than a legal one. To file Article 7(2) notifications defensibly you need evidence, not assertions. That evidence must survive four kinds of scrutiny:

• Internal audits: your own periodic review of declaration completeness.

• Customer (OEM) audits: buyers demanding proof of SVHC status per part.

• Regulatory inspections: Member State market surveillance authorities acting on ECHA data.

• Certification audits: ISO 9001, IATF 16949, and ISO 14001 assessors checking process control.

Each requires continuous audit-ready documentation: time-stamped declarations, an immutable log of who submitted what evidence and under what authority, and the ability to run a point-in-time query showing what you knew and when. Historic state tracking is a data-versioning problem, and it is the difference between a two-hour audit response and a two-week fire drill. No platform makes an organization "audit-proof," but the objective is realistic: fewer surprises and a faster, evidence-backed response. Our stay audit-ready use case describes this model, used in practice by trust-center approaches at large electronics and automotive OEMs.

Compliance Risks and Enforcement Exposure

Article 33 is enforced at Member State level, and penalties vary widely, from administrative fines to criminal sanctions in several states including Sweden, Germany, France, the Netherlands, and others. The more common commercial risk is quieter: a customer or marketplace requests an SVHC declaration you cannot produce, and the result is delisting or blocked shipments. In practice, the buyer's compliance gate arrives before the regulator does, which is why automated supplier data collection and portals are a revenue-protection tool as much as a compliance one.

Future Outlook: The Authorisation Track

Candidate List inclusion is the early-warning stage. Substances can later move to the Authorisation List (Annex XIV), after which use requires authorisation past a sunset date. ECHA opened a public consultation on 2 February 2026 recommending four substances for Annex XIV, with comments due 2 May 2026. n-Hexane and BPAF may be considered for authorisation in future rounds. The strategic read is that today's Article 7(2) notification is tomorrow's authorisation exposure, so regulatory intelligence and horizon scanning should track both stages together. Our analysis of the four-substance Annex XIV recommendation covers the pathway.

Compliance Preparation Checklist

✅ Screen the full 253-entry Candidate List against every active BOM, not just the two new substances.

✅ Separate the Article 33 population (>0.1% w/w) from the Article 7(2) population (>0.1% w/w AND >1 tonne/year).

✅ Confirm whether any Article 7(2) exemption applies before filing or omitting.

✅ Update Safety Data Sheets for affected substances and mixtures now, not in August.

✅ Submit or update SCIP notifications for affected articles.

✅ Prepare Article 7(2) notifications in IUCLID via REACH-IT ahead of 4 August 2026.

✅ Retain time-stamped supplier evidence for audit and customer requests.

You can pressure-test this with our Customer Audit Readiness Scorecard, a 20-question self-assessment across REACH, RoHS, Prop 65, PFAS, and conflict minerals.

AI-driven SVHC Candidate List screening workflow for REACH Article 7(2) notification

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How AI Changes SVHC Compliance at Scale

Manually mapping 253 entries against thousands of parts and multi-tier declarations is where most programs break. This is the problem Certivo's CORA-powered regulatory intelligence is built for. CORA scans the full Candidate List against your BOM automatically, flags every article above the 0.1% threshold, applies the one-tonne logic to identify the Article 7(2) population, and generates notification-ready records.

The underlying data comes from a centralized compliance data backbone fed by AI document parsing and certificate validation, so supplier declarations, test reports, and SDS files are read, structured, and checked without manual re-keying. When a new substance is listed, the same AI-native compliance automation re-screens the portfolio and surfaces the delta, turning a reactive scramble into continuous readiness. Explore how this works on the Certivo platform and in materials and environmental compliance.

To see how this applies to your product portfolio and supplier base, speak with a compliance specialist.