Most Substances of Very High Concern (SVHC) compliance failures are not caused by the chemistry. They are caused by confusion over three separate legal duties and by supplier paperwork that does not actually prove anything.

If a part contains an SVHC above 0.1% weight by weight (w/w), you may owe a communication duty to your customers, a notification to the European Chemicals Agency (ECHA), and a separate submission to the SCIP database. These obligations have different triggers, different thresholds, and different deadlines. Treating them as one requirement is where enterprise manufacturers get exposed.

This guide separates the three duties, explains exactly when each one applies, and defines what supplier documentation holds up as evidence. For teams managing this at scale, our REACH compliance framework page and materials and environmental compliance solution show how the data problem is handled centrally.

Book a compliance risk assessment to see where SVHC evidence gaps sit across your product portfolio and supply chain.

Key Takeaways

📌 An SVHC above 0.1% w/w in an article can trigger three separate obligations under EU law, each with its own rules.

🔗 REACH Article 33 requires you to communicate SVHC information to recipients and consumers, with no tonnage threshold.

📊 REACH Article 7(2) requires a notification to ECHA only when the SVHC exceeds both 0.1% w/w and 1 tonne per year, with specific exemptions.

📄 SCIP is a separate submission to ECHA under the Waste Framework Directive, mandatory since 5 January 2021, with no tonnage threshold.

⚠️ A blanket "REACH compliant" statement is not proof. Valid evidence names the substance, the concentration, the part, and the Candidate List version.

⏳ The Candidate List is typically updated twice a year, so supplier declarations must be re-validated, not collected once.

🤖 Continuous tracking, automated supplier data collection, and BOM-level substance mapping are the practical way to keep this current.

The three SVHC duties manufacturers confuse

Before any deadline question, you need to know which obligation you are actually looking at. Three duties sit on top of the same 0.1% concentration trigger but diverge from there.

1. Communicate SVHC information down the supply chain (REACH Article 33).

2. Notify ECHA about substances in articles (REACH Article 7(2)).

3. Submit a SCIP notification to ECHA under the revised Waste Framework Directive.

The first is a supplier-to-customer duty. The second and third both go to ECHA but rest on different laws and different triggers. The sections below define each one precisely.

What is an SVHC and the 0.1% threshold

An SVHC is a substance identified under Article 57 of REACH Regulation (EC) No 1907/2006 and placed on the Candidate List under Article 59. This includes carcinogens, mutagens, reproductive toxicants, PBT and vPvB substances, and substances of equivalent concern such as endocrine disruptors. ECHA maintains the authoritative Candidate List, which now holds more than 240 entries and is typically updated twice a year.

Inclusion on the Candidate List is the moment legal obligations attach. Several SVHCs are also PFAS, which connects this duty to broader PFAS chemical risk management programs.

Does 0.1% apply to the whole product or each component?

This is the detail that catches large manufacturers. Following the Court of Justice of the European Union ruling in Case C-106/14 (September 2015), the 0.1% w/w threshold applies to each article incorporated into a complex product, not to the total weight of the finished assembly. ECHA refers to this as the "once an article, always an article" principle in its guidance on substances in articles.

For an enterprise with multi-level bills of materials, this means the threshold must be assessed at the component level. A small part with a high SVHC concentration can trigger duties even when the substance is diluted across the full product. This is a core reason SVHC control belongs in BOM-level compliance tracking rather than in product-level spreadsheets.

When you must communicate an SVHC under REACH Article 33

Article 33 is a communication duty, not a government filing. It applies to any supplier of an article containing a Candidate List SVHC above 0.1% w/w, and it has no tonnage threshold.

• Article 33(1): When you supply an article to an industrial or professional recipient or a distributor, you must provide sufficient information for safe use, as a minimum the name of the SVHC.

• Article 33(2): On request from a consumer, you must provide the same information within 45 days, free of charge.

The practical implication is that even a single affected part obliges you to pass substance information to your customers. Many OEM customer audits now test this directly by asking for the SVHC name and concentration at the part level. Meeting those requests quickly is a function of how well your supplier documentation is organized.

Comparison of REACH Article 33, Article 7(2), and SCIP SVHC notification requirements

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When you must notify ECHA under REACH Article 7(2)

Article 7(2) is a true notification to ECHA, and it is the duty most often over-applied. It falls only on producers and importers of articles, not distributors, and it requires two conditions to be met together:

• The SVHC is present above 0.1% w/w, and

• The SVHC is present in those articles in quantities totalling over 1 tonne per producer or importer per year.

The timing rule is set by Article 7(7): the notification must be made no later than six months after the substance is added to the Candidate List. For newly placed products, the duty applies from the point the article is produced or imported above the thresholds. You can review the official position on ECHA's substances in articles page.

Article 7(2) exemptions

Two exemptions materially reduce how often this notification is actually required:

• Article 7(3): No notification is needed if exposure to the substance can be excluded during normal and reasonably foreseeable conditions of use, including disposal. In that case, you must still supply appropriate use instructions to the recipient.

• Article 7(6): No notification is needed if the substance has already been registered for that use.

Because many SVHCs used in articles are already registered, Article 7(2) notifications are, in practice, less frequent than Article 33 communication and SCIP submissions. A compliance team should confirm registration status before assuming a filing is due, which is where CORA-powered regulatory intelligence helps distinguish a genuine Article 7(2) trigger from a false one.

When you must submit a SCIP notification

SCIP (Substances of Concern In articles as such or in complex objects/Products) is a separate obligation that sits under waste law, not REACH directly. The legal basis is Article 9(1)(i) of the revised Waste Framework Directive (Directive 2008/98/EC as amended by Directive (EU) 2018/851), available on EUR-Lex.

Key points for enterprise manufacturers:

• SCIP has applied since 5 January 2021.

• It covers articles containing a Candidate List SVHC above 0.1% w/w, with no tonnage threshold.

• The duty falls on EU suppliers placing articles on the market, including producers, importers, assemblers, and distributors.

• Retailers and other actors supplying articles directly and exclusively to consumers are not required to submit SCIP notifications.

SCIP is the duty with the broadest reach, because any affected part placed on the EU market generates a submission obligation regardless of volume. ECHA's Understanding SCIP resources set out the data elements required. Note that SCIP is an EU mechanism; UK REACH operates separate SVHC duties and does not include a SCIP database.

What supplier paperwork actually counts as proof

"What proof do I need?" is where most SVHC programs break down. A declaration that says "our products are REACH compliant" is not evidence. It names no substance, no concentration, and no part, so it cannot support an Article 33 response, a SCIP dossier, or a customer audit.

Documentation that holds up as evidence usually takes one of these forms:

• Full Material Declarations (FMD): article-level disclosure, for example in IPC-1752A Class D format, listing substances and concentrations.

• IEC 62474 declarations: common in electronics, mapping declarable substances against the current list.

• SVHC or REACH declarations: statements that name the specific Candidate List substances present above 0.1% w/w, or affirm none are present, at the part level.

• Certificates of Conformance and analytical test reports: supporting evidence such as laboratory analysis or screening data for a specific part.

One frequent error is treating a Safety Data Sheet (SDS) as article proof. An SDS covers substances and mixtures, not articles, so it does not by itself satisfy article-level SVHC obligations. Certivo accepts supplier evidence in multiple formats rather than forcing a single template, as explained in our IPC-1752A disclosure article.

What makes a declaration valid

A declaration counts as proof when it:

✓ Identifies the specific part or article, traceable to your BOM.
✓ Names the SVHC(s) present above 0.1% w/w, or affirms none are present.
✓ States the concentration or confirms the sub-threshold position.
✓ References the Candidate List version or date it was assessed against.
✓ Identifies the responsible supplier and signatory, with a date.

Declarations missing any of these elements create gaps that surface during customer audits and regulatory inspections. Building this evidence into audit-ready documentation is what lets a team retrieve proof on demand rather than reconstruct it under pressure.

Checklist of what makes a supplier SVHC declaration valid proof for REACH and SCIP

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Why SVHC proof is a moving target

An SVHC declaration is only accurate against the Candidate List that existed when it was signed. Because ECHA typically adds substances twice a year, a declaration collected in one cycle can be incomplete after the next update.

This is the structural weakness in one-time supplier data collection. A part that was below threshold last year can become reportable the moment a new substance is listed, with no change to the part itself. Recent additions covered in our blogs on two new Candidate List substances and the DBDPE listing show how quickly scope shifts. Treating SVHC control as continuous monitoring, rather than an annual campaign, is the difference between staying current and discovering a gap during an audit.

The operational challenge: multi-tier supplier data at scale

For a global manufacturer, the regulatory rules are the simple part. The hard part is collecting accurate, part-level declarations from hundreds or thousands of suppliers, many of whom sit two or three tiers deep in the chain.

This creates real cost and risk for leadership. For the CFO, it is the labor cost of chasing and validating declarations. For compliance and quality, it is the exposure when a customer or authority requests evidence that cannot be produced quickly. For supply chain teams, it is the difficulty of mapping substances to specific parts across complex electronics and industrial bills of materials. Manual spreadsheet processes do not scale to this, which is why many manufacturers move SVHC data into a centralized supplier and contractor management system.

Struggling to collect part-level SVHC declarations across tiers? Book a compliance review to see how the data flow can be automated.

How Certivo and CORA support SVHC and SCIP compliance

Certivo operates as the centralized system of record for product compliance, with CORA providing the embedded regulatory intelligence. For SVHC and SCIP specifically, that combination addresses the three failure points described above.

• Regulatory intelligence: CORA-powered regulatory intelligence tracks Candidate List updates so affected parts are flagged when new substances are listed, rather than at the next audit.

• Automated supplier data collection: supplier portals gather part-level declarations in multiple formats and chase missing responses, reducing manual follow-up across tiers.

• AI document parsing and certificate validation: uploaded declarations and test reports are read and checked for the elements that make them valid, flagging blanket statements that name no substance.

• BOM-level substance mapping: declarations are tied to specific parts and bills of materials, supporting the per-article 0.1% assessment and SCIP dossier preparation.

The goal is not to claim software removes compliance risk. It is to reduce surprises, speed up evidence retrieval, and keep the manufacturer audit-ready as the Candidate List evolves. For broader context, see our guide to materials and environmental compliance.

Key compliance actions

1. Assess the 0.1% w/w threshold at the component level, not the finished product.

2. Separate the three duties: Article 33 communication, Article 7(2) ECHA notification, and SCIP submission.

3. Confirm registration status and exposure exclusion before assuming an Article 7(2) notification is due.

4. Re-validate supplier declarations against the current Candidate List after each update.

5. Require declarations that name the substance, concentration, part, and list version, and reject blanket statements.

6. Centralize SVHC evidence so it can be retrieved on demand for customer audits and inspections.

Enforcement and penalties for REACH and the Waste Framework Directive are set and applied at Member State level and vary by country, which makes consistent, retrievable evidence the practical priority across every jurisdiction you sell into.

Get a compliance risk assessment to map your current SVHC and SCIP exposure across products and suppliers.