REACH SVHC Compliance: Supply Chain Requirements for EU Electronics

REACH is the EU’s comprehensive regulation on chemicals. For consumer electronics importers and manufacturers, the operational focus is on Substances of Very High Concern (SVHC) in articles — the physical products you sell, not just the chemicals used to make them. REACH obligations are ongoing: the SVHC candidate list is updated twice a year, and a product that was compliant in 2022 may require new declarations and customer notification today.

Overview

Regulation EC 1907/2006 (REACH) is administered by the European Chemicals Agency (ECHA). It entered into force in 2007 and is enforced by national authorities in each EU member state (e.g., BfR/UBA in Germany, HSE in the UK pre-Brexit).

REACH covers Registration, Evaluation, Authorisation and Restriction of Chemicals. For article producers and importers, the most relevant obligations are:

Article 33: If an article contains an SVHC above 0.1% w/w, you must inform B2B customers within 45 days of request, and inform consumers proactively (without request).
Article 7(2): If an article contains an SVHC in quantities above 1 tonne/year per producer/importer AND above 0.1% w/w in the article, you must notify ECHA. (Exceptions apply for substances with a standard notification-exempt status.)
SCIP Database: Since January 5, 2021, suppliers placing articles on the EU market that contain SVHCs above 0.1% w/w must submit information to ECHA’s SCIP database (Substances of Concern In articles as such, or in complex objects — Products). This feeds into waste management systems.

The SVHC Candidate List is updated twice yearly (typically June and December). As of early 2026, it contains 240+ substances. Substances on the Candidate List may later be added to the Authorisation List (Annex XIV), at which point their use is prohibited unless specifically authorized.

Applicability

REACH SVHC obligations apply to:

Any company established in the EU that produces or imports articles into the EU
Non-EU companies’ EU-based importers or authorized representatives

For electronics specifically, PCB assembly products carry the highest SVHC exposure risk:

PCB laminates: Certain flame retardants, plasticizers (DEHP), and surface treatments
Cable insulation and connectors: Phthalate plasticizers (DEHP, DBP, BBP, DIBP) in PVC
Housing and enclosures: Phthalates, brominated flame retardants in ABS and polycarbonate
Metal components: Boric acid, lead compounds in certain alloys
Adhesives and coatings: Various organic compounds on the candidate list

Note: RoHS and REACH overlap but are distinct. RoHS restricts specific substances below set limits. REACH requires disclosure and notification above 0.1% — there is no automatic ban at that threshold (unless the substance reaches the Authorisation List).

Key Requirements

The 0.1% threshold applies to the weight of the whole article, not a homogeneous material as in RoHS. An SVHC at 0.5% in a 2g PCB coating represents 0.5% of that component, but may be well below 0.1% of the total product weight.

Article 33 disclosure chain: Works down the supply chain. Your component supplier must tell you if SVHC is >0.1% in their article. You must pass that information to your customers. This creates supply chain transparency obligations that require active management.

Key SVHCs commonly found in electronics supply chains:

DEHP (CAS 117-81-7): Phthalate plasticizer in PVC cables, gaskets, and some PCB materials
Lead and lead compounds: Various CAS numbers, found in solder (leaded), brass alloys, some pigments
Boric acid (CAS 10043-35-3): Used in some flux formulations
Diisodecyl phthalate (DIDP) and Diisononyl phthalate (DINP): Cable insulation
Bis(2-ethylhexyl) phthalate (DEHP): Multiple applications
Nonylphenol ethoxylates (NPE): Surfactants in cleaning processes

Process & Timeline

Step 1: Map your supply chain for SVHC exposure. For each product, identify which components and materials have the highest SVHC risk: cables (phthalates in PVC), connectors (Pb in brass), PCB (flame retardants, coatings), housing (plasticizers).

Step 2: Request SVHC declarations from your supply chain. Use a standardized format:

IPC-1752A Class C: Industry standard, covers SVHC in addition to RoHS substances. Widely used in electronics supply chains.
SCIP notification reference: Suppliers subject to SCIP can share their SCIP reference number.
Request declarations annually — the candidate list changes twice a year.

Step 3: Assess each declaration against the current candidate list. Cross-reference the substances declared against the current ECHA SVHC candidate list (searchable at echa.europa.eu). A substance not on the list when declared may have been added since.

Step 4: SCIP database submission. For each article you supply into the EU that contains SVHC >0.1% w/w, submit a SCIP notification via the ECHA SCIP portal. Required information: article name, identifiers (CAS/EC number of SVHC), concentration range, safe use information. SCIP submission is per product, not per shipment.

Step 5: Customer notification. For B2B sales: provide SVHC information within 45 days of request. For consumer sales (B2C): provide information proactively at point of sale.

Timeline: Initial supply chain mapping and declaration collection: 4–10 weeks depending on tier-2 supplier responsiveness. SCIP submission: 1–2 days per product once data is collected.

Chemical testing costs (verification):

GC-MS for phthalates: $300–800 per material/component
ICP-MS for metals (lead compounds, chromium): $200–600 per component
Full SVHC screening for one product (5–10 components): $1,500–4,000

Getting It Done from China

REACH SVHC obligations are a supply chain exercise, not a certification. Chinese Tier-1 manufacturers dealing with EU customers regularly maintain SVHC declarations and can provide them on request with reasonable turnaround (5–15 business days). Smaller component suppliers and distributors may not have systematic records.

When onboarding new Chinese suppliers, include REACH SVHC declaration requirements in your supplier agreement:

Annual declaration, IPC-1752A Class C format or equivalent
Notification within 30 days of any SVHC addition to the candidate list that affects supplied components
Right to audit chemical compliance records

For SCIP notifications, ECHA provides a free SCIP submission tool. Some EU importers use services from compliance consultancies (e.g., Compliance Gate, Chemical Watch data services) for automated SCIP filing and candidate list monitoring.

Common Mistakes

Building SVHC declaration collection into your pre-production inspection checklist ensures documentation is in hand before goods ship.

1. Using static declarations from previous years. The SVHC candidate list is updated twice annually. A declaration from 2022 does not cover substances added to the list in 2023 or 2024. Establish a process for annual renewal of supplier declarations and automatic cross-referencing against the current list.

2. Confusing REACH and RoHS. RoHS restricts specific substances below concentration limits — you must keep them out. REACH SVHC requires disclosure and notification above 0.1% — the substance is allowed in the product (unless it reaches the Authorisation List), but you must tell customers. Many importers incorrectly believe that a RoHS-compliant product is automatically REACH-compliant; the substance lists overlap but are distinct.

3. Not submitting to SCIP. SCIP has been mandatory since January 2021 for all EU article suppliers. Non-compliance is an enforcement risk as national authorities begin using SCIP data for market surveillance. Many smaller importers still have not set up SCIP submissions.

RoHS 2 Compliance — overlapping restricted substance requirements for the same products
CE Marking for Electronics — the broader declaration framework that REACH feeds into
Quality Inspection Services
Consumer Electronics Sourcing
PCB Manufacturing & SMT Sourcing
How to Source Electronics from China