EU importers of articles
Article 33 communication, ECHA notification above one tonne a year, SCIP submissions and compliance with Annex XVII restrictions.
EU · Chemicals · Regulation (EC) No 1907/2006
REACH: know what is in every material.
Under REACH (Regulation (EC) No 1907/2006), any supplier of an article containing a Candidate List substance of very high concern (SVHC) above 0.1% weight by weight must give its customers enough information for safe use, at minimum the substance name (Article 33). Separately, Annex XVII restrictions set hard limits for specific substances, such as PFHxA from 10 October 2026 and formaldehyde release since 6 August 2026.
- 0.1% w/w
- SVHC threshold, per article
- 45 days
- to answer a consumer request
- 6 months
- to notify ECHA after listing
Status · checked 28 Sep 2026 PFHxA limits from 10 Oct 2026
- SCIP notifications begin
- Formaldehyde release limits for articles
- 28 Sep 2026
- PFHxA restriction, first phase
- PFHxA restriction, second phase
The short answer
What you need to know.
Checked against official sources on 28 September 2026.
- 01
REACH has two tools that matter most to importers of finished goods: the Candidate List of SVHCs, which triggers information duties, and Annex XVII, which restricts specific substances outright.
- 02
Article 33: if an article contains a Candidate List SVHC above 0.1% w/w, tell your business customers, and consumers on request within 45 days, enough for safe use, at least the substance name. The threshold applies to each article in a complex product (CJEU, C-106/14).
- 03
Article 7(2): importers notify ECHA when an SVHC is above 0.1% and above one tonne per year across their articles, within six months of it joining the Candidate List. Since 5 January 2021 article suppliers also submit Article 33 information to ECHA’s SCIP database.
- 04
ECHA adds substances to the Candidate List over time, and each addition can create duties straight away. Supplier declarations should name the list version they were checked against.
- 05
Annex XVII dates to plan for: formaldehyde release limits for articles since 6 August 2026; PFHxA limits in consumer clothing, footwear, food-contact paper, consumer mixtures and cosmetics from 10 October 2026, and in other consumer textiles from 10 October 2027.
Who it applies to
Every supplier of articles passes information on.
Wholesalers and retailers
Article 33 applies to any supplier of an article, so the SVHC information travels with the goods to the shelf.
Consumer product brands
Answer consumer requests within 45 days and make sure restricted substances stay below Annex XVII limits.
Suppliers in India, China, Vietnam
Not bound by REACH directly, but the only ones who know what went into each material. Their declarations and test data make your compliance possible.
Key dates
Every date, with its source.
Dates set in the REACH restriction regulations. Candidate List additions happen on ECHA’s own schedule; check the live list.
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SCIP notifications begin
Suppliers of articles provide Article 33 information to ECHA under the Waste Framework Directive.
-
Formaldehyde release limits for articles
No more than 0.062 mg/m³ for furniture and wood-based articles and 0.080 mg/m³ for other articles, under the Appendix 14 test conditions.
- Today · 28 September 2026
-
PFHxA restriction, first phase
PFHxA and its salts below 25 ppb, PFHxA-related substances below 1,000 ppb, in consumer clothing textiles, leather and accessories; consumer footwear; food-contact paper and board; consumer mixtures; cosmetics. Articles placed on the market before this date are exempt.
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Formaldehyde limit for vehicle interiors
0.062 mg/m³ in the interior of road vehicles.
-
PFHxA restriction, second phase
The same limits for consumer textiles, leather, furs and hides other than clothing and accessories, such as home textiles.
Three duties, one list
What a Candidate List SVHC triggers.
For an SVHC above 0.1% weight by weight in an article you import into the EU.
| Duty | Who | Trigger | Timing |
|---|---|---|---|
| Inform business customers (Art. 33(1)) | Any supplier of the article | SVHC above 0.1% w/w | With the article, at least the substance name |
| Answer consumers (Art. 33(2)) | Any supplier of the article | A consumer request | Within 45 days, free of charge |
| Notify ECHA (Art. 7(2)) | Producer or importer of articles | SVHC above 0.1% and above 1 tonne per year | Within 6 months of listing |
| SCIP database | Suppliers of articles | SVHC above 0.1% w/w | Since 5 January 2021 |
The Article 7(2) notification is not needed where exposure to humans and the environment can be excluded during normal use and disposal (Art. 7(3)).
What you need from suppliers
What to ask your factory and its suppliers.
Declarations are only as good as the material data behind them. We collect both.
- SVHC declaration per articleSigned, naming the Candidate List version checked, and stating any SVHC above 0.1% w/w per component.
- Bill of materials by componentFabrics, coatings, plastics, foams, inks, adhesives and metal parts, with the supplier of each.
- Material supplier dataSafety data sheets and declarations from the fabric mill, compounder or coating supplier.
- Test reports for Annex XVII entriesFrom accredited labs, for the restrictions that apply to your product, such as PFHxA or formaldehyde release.
- Change notificationsA commitment to tell you before any material, supplier or process change.
- Re-confirmation after list updatesAn updated declaration each time ECHA adds substances to the Candidate List.
How SourceSquid helps
From your product list to an audit-ready file.
Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs.
- 01
Material mapping
Every SKU broken down into articles and materials, with the supplier behind each one.
You receiveMaterial and supplier map - 02
Risk-based screening
Substances likely in each material identified, so testing goes where it counts.
You receiveChemical risk matrix - 03
Lab testing
Samples drawn by our inspectors and sent to accredited labs in India or China.
You receiveTest plan and reports - 04
Declarations managed
Supplier declarations collected, checked and refreshed after every Candidate List update.
You receiveDeclaration register - 05
Article 33 and SCIP data
The information your customers and ECHA need, prepared per article.
You receiveCommunication-ready data - 06
Watch and alert
New restrictions and Candidate List changes mapped to your products.
You receiveCompliance Radar updates
Sources
Official texts behind this page
Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser.
- Regulation (EC) No 1907/2006 (REACH)Arts. 7(2), 7(7), 33, 57, 59, 67; Annex XVII
- ECHA: Candidate List of substances of very high concern for Authorisation
- Commission Regulation (EU) 2024/2462: PFHxA, its salts and related substancesAnnex XVII entry 79
- Commission Regulation (EU) 2023/1464: formaldehyde and formaldehyde releasersAnnex XVII entry 77
- Directive (EU) 2018/851 amending the Waste Framework Directive (SCIP)Art. 9(1)(i) of Directive 2008/98/EC
- Court of Justice of the EU, Case C-106/14 (FCD and FMB)0.1% threshold applies to each article
Related compliance guides
Rules that often travel together.
EU · packagingPPWRPackaging and Packaging Waste Regulation (EU) 2025/40: conformity, substances, labels and recyclability.→DE · FR · EUPackaging EPRExtended producer responsibility in Germany (LUCID, VerpackDG) and France (Triman, IDU).→Management systemsISO 9001 and 14001Quality and environmental certification for suppliers, including the 2026 editions.→
REACH questions
Straight answers.
Dates checked against official sources. We update this page when the rules move.
[email protected]What is a REACH SVHC supplier declaration?
It is the supplier’s statement of whether an article contains any substance on ECHA’s Candidate List of substances of very high concern (SVHC) above 0.1% weight by weight, and if so which one. It supports the importer’s duty under Article 33 of REACH to pass that information on to customers, at minimum the substance name. A useful declaration names the Candidate List version it was checked against.
Does the 0.1% SVHC threshold apply to the whole product or each part?
To each article. In Case C-106/14 (2015) the Court of Justice of the EU held that when a product is made of several articles, the 0.1% threshold applies to each article incorporated in it, not to the complex product as a whole. So a bag’s zip, strap and lining are each assessed.
How quickly must I answer a consumer who asks about SVHCs?
Within 45 days of receiving the request, free of charge, if the article contains a Candidate List substance above 0.1% weight by weight. The answer must give enough information for safe use, including at least the name of the substance (Article 33(2)).
When must an importer notify ECHA about an SVHC in articles?
When a Candidate List substance is present in its articles above 0.1% weight by weight and in quantities totalling over one tonne per importer per year, unless exposure can be excluded. The notification is due no later than six months after the substance is added to the Candidate List (Article 7(2) and 7(7)). Separately, suppliers of such articles provide the Article 33 information to ECHA’s SCIP database.
What is the difference between the Candidate List and Annex XVII?
The Candidate List triggers information duties: communication, notification and SCIP. Annex XVII sets restrictions: substances that may not be placed on the market above set limits in certain products. For example, PFHxA is restricted in consumer clothing, footwear and food-contact paper from 10 October 2026, and furniture and other articles may not release formaldehyde above set limits since 6 August 2026.
Start here
Chemical compliance, settled at the factory.
Send us your product list and materials. We return a REACH risk matrix and a test plan sized to what your products really need.