REACH 1907/2006: chemical substances and SVHC
Regulation (EC) No 1907/2006, known as REACH, was adopted on 18 December 2006 and entered into force on 1 June 2007. For an electronics maker it rarely means registering a substance: it means tracking the Candidate List of substances of very high concern (SVHC), which held 253 entries after its 4 February 2026 update, communicating under Article 33 for each component article above 0.1 % weight by weight, notifying SCIP under the Waste Framework Directive, and checking the Annex XIV and Annex XVII entries that reach components. This guide reads those duties from the consolidated text of 22 June 2026 and the 2015 judgment of the Court of Justice in case C-106/14, and lists the claims the texts contradict.
The texts, dated
Section titled “The texts, dated”| Date | Event | Source |
|---|---|---|
| 18 December 2006 | REACH adopted | Regulation (EC) No 1907/2006 |
| 1 June 2007 | Entry into force | Article 141(1) |
| 1 June 2008 | Titles II (registration), III, V, VI (evaluation), VII (authorisation), XI and XII apply | Article 141(2) |
| 1 June 2009 | Title VIII and Annex XVII (restrictions) apply | Article 141(4) |
| 1 June 2011 | Article 7(2) notification applies six months after a substance is listed | Article 7(7) |
| 10 September 2015 | Court of Justice rules that the 0.1 % applies to each article in a complex product | C-106/14 |
| 5 January 2021 | Suppliers of articles must send Article 33(1) information to ECHA (SCIP) | Directive 2008/98/EC, Article 9(1)(i) |
| 29 November 2024 | Lead in PVC articles restricted (entry 63, paragraph 15) | Regulation (EU) 2023/923 |
| 5 November 2025 | DBDPE added to the Candidate List (vPvB, flame retardant), 251 entries | ECHA, via Intertek |
| 4 February 2026 | n-hexane and bisphenol AF added, 253 entries | ECHA, via CIRS |
| 26 March 2026 | RAC final opinion and SEAC draft opinion on universal PFAS restriction released | ECHA, via Arnold & Porter |
| 27 April 2026 | Commission says it will not open REACH for revision at this point | European Parliament legislative train |
| 22 June 2026 | Latest consolidated version of REACH (includes Regulation (EU) 2026/1168) | EUR-Lex |
| 10 October 2026 | PFHxA restriction starts for clothing textiles, footwear, food contact paper, consumer mixtures and cosmetics | Entry 79, paragraph 1 |
| 23 December 2026 | DMAC and NEP worker exposure conditions apply | Entries 80 and 81 |
| 10 May 2027 | 2,4-dinitrotoluene restricted in articles at 0.1 % | Entry 83 |
The ECHA website blocked automated reads when this page was updated on 7 October 2026, so the Candidate List count of 253 comes from the 4 February 2026 update as reported by CIRS. No later update was found in published sources; check the live ECHA table before relying on the number.
The four pillars of REACH
Section titled “The four pillars of REACH”| Pillar | Title and articles | What it does |
|---|---|---|
| Registration | Title II, Articles 5 to 24 | Manufacturers and importers register each substance above 1 tonne per year; a chemical safety report is needed from 10 tonnes (Article 14) |
| Evaluation | Title VI, Articles 40 to 54 | ECHA checks dossiers; Member States evaluate substances listed in the rolling action plan (CoRAP) |
| Authorisation | Title VII, Articles 55 to 66 | Substances in Annex XIV need an authorisation per use after their sunset date |
| Restriction | Title VIII, Articles 67 to 73 | Annex XVII bans or conditions manufacture, placing on the market or use |
Article 1 states the purpose: a high level of protection of human health and the environment, including the promotion of alternative methods for hazard assessment, together with the free circulation of substances on the internal market while enhancing competitiveness and innovation.
Registration and articles
Section titled “Registration and articles”Registration is mainly a duty of chemical manufacturers and importers. For articles, Article 7 sets two separate duties:
- Article 7(1), registration: a producer or importer of articles registers a substance only if it is present above one tonne per year and intended to be released under normal or reasonably foreseeable conditions of use.
- Article 7(2), notification: a producer or importer of articles notifies ECHA when a Candidate List substance is present above one tonne per year in those articles and above 0.1 % weight by weight. Article 7(3) removes the duty where exposure can be excluded, including at disposal, and Article 7(6) where the substance is already registered for that use. Under Article 7(7), the duty applies six months after the substance is listed.
Authorisation
Section titled “Authorisation”A Candidate List substance can move to Annex XIV by a Commission decision under Article 58, after an ECHA recommendation that takes into account the opinion of the Member State Committee. Each entry fixes a latest application date and a sunset date. After the sunset date, placing on the market and use are prohibited unless an authorisation is granted. Article 60(2) grants it when the risk is adequately controlled; Article 60(4) allows it when socio-economic benefits outweigh the risk and no suitable alternative exists. Article 60(3) closes the first route to PBT and vPvB substances and to substances without a determinable threshold.
The consolidated text of 22 June 2026 has 59 Annex XIV entries. They include DEHP, BBP, DBP and DIBP (entries 4 to 7), three lead chromate pigments (entries 10 to 12), chromium trioxide and several chromates (entries 16 to 22, 28 to 31), and four UV absorbers, UV-328, UV-327, UV-350 and UV-320 (entries 51 to 54).
Restriction: Annex XVII entries that reach electronics
Section titled “Restriction: Annex XVII entries that reach electronics”| Entry | Substance | What it restricts | Note for electronic equipment |
|---|---|---|---|
| 23 | Cadmium | Mixtures and articles of listed polymers, paints, brazing, jewellery | Read with RoHS for equipment |
| 51 | DEHP, BBP, DBP, DIBP | Articles above 0.1 % of the plasticised material from 7 July 2020 | Paragraph 4(h) excludes equipment within RoHS scope |
| 63 | Lead and compounds | Jewellery, articles that children can mouth, gunshot in wetlands, and from 29 November 2024 PVC articles at 0.1 % of the PVC | Paragraph 19(c)(ii) excludes PVC articles within RoHS scope |
| 74 | Diisocyanates | Use above 0.1 % unless users are trained | Adhesives, foams and coatings used in assembly |
| 78 | Synthetic polymer microparticles | Placing on the market on their own or in mixtures at 0.01 % or more | Paragraph 4(a) exempts placing on the market for use at industrial sites |
| 79 | PFHxA and related substances | Textiles, footwear, food contact paper, consumer mixtures, cosmetics, firefighting foams, from 10 April 2026 to 10 October 2029 depending on use | Electronic equipment is not a listed use |
| 80, 81 | DMAC, NEP | Substance or mixtures at 0.3 % or more after 23 December 2026, unless worker exposure levels are documented and met | Process solvents |
| 82 | PFAS in firefighting foams | From 23 October 2030 at 1 mg/L, with transition periods | Not product related |
| 83 | 2,4-dinitrotoluene | Articles at 0.1 % after 10 May 2027 | Exclusions for explosives, toys and medical devices |
SVHC: criteria and the Candidate List
Section titled “SVHC: criteria and the Candidate List”An SVHC is a substance meeting one of the criteria of Article 57 and identified through Article 59.
| Article 57 | Criterion | Example on the list |
|---|---|---|
| (a) | Carcinogenic category 1A or 1B | Chromium trioxide |
| (b) | Germ cell mutagenic category 1A or 1B | |
| (c) | Toxic for reproduction category 1A or 1B | DEHP, bisphenol AF (2026) |
| (d) | PBT under Annex XIII | HBCDD |
| (e) | vPvB under Annex XIII | DBDPE (2025) |
| (f) | Equivalent level of concern, such as endocrine disruption | DEHP (endocrine), n-hexane (2026) |
Article 59 sets the procedure. The Commission may ask ECHA, or a Member State may decide, to prepare an Annex XV dossier. ECHA publishes a notice and invites comments from interested parties within a deadline it specifies; Member States and ECHA have 60 days to comment. Without comments, ECHA lists the substance. With comments, the Member State Committee has 30 days to reach unanimous agreement; failing unanimity, the Commission prepares a draft decision, adopted under the committee procedure of Article 133(3).
The Candidate List carries no ban. Listing triggers Article 7(2), Article 33 and SCIP, and it is the pool from which Annex XIV entries are chosen.
Article 33 and judgment C-106/14
Section titled “Article 33 and judgment C-106/14”Article 33(1) applies to any supplier of an article containing a Candidate List substance above 0.1 % weight by weight. The supplier must give the recipient sufficient information, available to it, to allow safe use of the article, including as a minimum the name of the substance. Under Article 33(2), a consumer who asks receives the same information, free of charge, within 45 days of the request.
The text does not say 0.1 % of what. The Court of Justice answered on 10 September 2015 in case C-106/14 (FCD and FMB):
- an object that meets the definition of an article in Article 3(3) does not stop being an article when it is assembled with others into a complex product; it remains one as long as it keeps a special shape, surface or design, and stops being one only when it becomes waste (paragraphs 52 and 53);
- for Article 7(2), the importer of a product made of several articles assesses each article against 0.1 %;
- for Article 33, the supplier of a product with one or more constituent articles above 0.1 % must inform the recipient, and the consumer on request, giving at least the substance name.
The industry shorthand is "once an article, always an article". For a printed circuit board assembly, the connector, the cable, the housing and each component are separate articles. A connector with an SVHC above 0.1 % of the connector triggers Article 33 even if the substance is far below 0.1 % of the whole device.
The SCIP database is not created by REACH. Directive (EU) 2018/851 inserted point (i) into Article 9(1) of the Waste Framework Directive 2008/98/EC: Member States must ensure that any supplier of an article as defined in point 33 of Article 3 of REACH provides the Article 33(1) information to ECHA from 5 January 2021. Article 9(2) required ECHA to set up the database by 5 January 2020, and to give access to waste treatment operators and, on request, to consumers.
Three consequences follow from that wording:
- the trigger is the Article 33(1) trigger, so the per article reading of C-106/14 applies to SCIP too;
- the duty is national law transposing a directive, so penalties are set by each Member State;
- the duty falls on suppliers under REACH Article 3(33), which covers producers, importers, distributors and other actors placing an article on the market. Article 33(1) information goes to recipients, which REACH Article 3(35) defines as industrial or professional users and distributors, not consumers.
REACH and RoHS
Section titled “REACH and RoHS”| Axis | REACH | RoHS |
|---|---|---|
| Act | Regulation (EC) 1907/2006 | Directive 2011/65/EU |
| Products | Substances, mixtures and articles of all sectors | Electrical and electronic equipment |
| Substances | Candidate List, Annex XIV, Annex XVII | Ten substances in Annex II |
| Threshold basis | 0.1 % of each article for Article 33; entry specific for Annex XVII | Homogeneous material |
| Marking | None | CE marking and EU declaration of conformity |
| Updates | Candidate List additions, annex amendments by Commission regulation | Delegated directives on substances and exemptions |
The two regimes apply to the same device. Where Annex XVII overlaps with RoHS, some entries step aside: entry 51 for the four phthalates and entry 63 for lead in PVC both exclude equipment within RoHS scope. Article 33 and SCIP have no such exclusion.
REACH-like regimes outside the Union
Section titled “REACH-like regimes outside the Union”| Country or region | Act |
|---|---|
| United Kingdom | UK REACH |
| South Korea | Act on the Registration and Evaluation of Chemicals (K-REACH) |
| Turkey | KKDIK |
| China | MEE Order 12, new chemical substances |
| United States | Toxic Substances Control Act (TSCA) |
| Japan | Chemical Substances Control Law |
None of these regimes recognises an EU registration or EU Candidate List screening. Each needs its own check.
Universal PFAS restriction
Section titled “Universal PFAS restriction”In January 2023, the authorities of Denmark, Germany, the Netherlands, Norway and Sweden submitted to ECHA a restriction proposal covering the per- and polyfluoroalkyl substances. The RAC final opinion and the SEAC draft opinion were released on 26 March 2026; the consultation on the SEAC draft ran to 25 May 2026 and SEAC is expected to finalise its opinion by the end of 2026. The Commission then prepares any Annex XVII entry; nothing has been adopted yet for electronic equipment.
The definition already used in entry 82 (any substance with at least one fully fluorinated methyl or methylene carbon atom) shows why fluoropolymers such as PTFE, PVDF, FEP and ETFE are in the discussion: they are used in cable insulation and lithium-ion cell binders. Semiconductor manufacturing is one of the sectors where the committees considered longer, time-limited derogations.
Claims the texts contradict
Section titled “Claims the texts contradict”| Common claim | What the text says |
|---|---|
| "The 0.1 % is computed on the finished product" | C-106/14: each article in a complex product keeps its article status; the 0.1 % applies to each article |
| "The Candidate List had more than 240 substances on 1 January 2026" | It had 251 entries from 5 November 2025 and 253 after 4 February 2026 |
| "REACH has applied since 1 June 2007" | That is entry into force; most titles applied from 1 June 2008, Annex XVII from 1 June 2009 (Article 141) |
| "Articles only matter through Article 33" | Article 7(2) also requires a notification to ECHA above 1 tonne per year and 0.1 % |
| "SVHC identification has a 45-day public consultation set by REACH" | Article 59(4) leaves the deadline to ECHA; Article 59(5) gives Member States and ECHA 60 days; the 45 days in REACH are the consumer reply deadline of Article 33(2) |
| "Entry 76 is lead in ammunition in wetlands" | Entry 76 is N,N-dimethylformamide; lead gunshot in wetlands is paragraph 11 of entry 63 |
| "The lead in PVC restriction applies to electronic equipment" | Entry 63, paragraph 19(c)(ii) excludes articles within the scope of Directive 2011/65/EU |
| "The microplastics restriction hits encapsulants and resins in devices" | Entry 78 restricts microparticles placed on the market on their own or in mixtures, and exempts placing on the market for use at industrial sites |
| "Annex XIV has more than fifty entries" | It has 59 in the consolidated text of 22 June 2026 |
| "The Toy Regulation 2009/48/EC" | 2009/48/EC is a directive; Annex XVII entry 83 already refers to the Toy Safety Regulation (EU) 2025/2509 |
| "A SCIP failure means withdrawal of the article" | SCIP comes from a directive; penalties are set in national law |
| "The REACH revision proposal is expected after 2026" | On 27 April 2026 the Commission said it would not open REACH at this point |
Relationship with other regimes
Section titled “Relationship with other regimes”REACH is not a harmonisation act under the New Legislative Framework: no CE marking, no notified body. It sits next to acts that electronics makers meet every day.
RoHS (Directive 2011/65/EU) applies to its ten substances in EEE. For CE marking and documentation, see the CE marking guide and the CE scope, and the RoHS guide.
Battery Regulation (EU) 2023/1542 (see the Battery Regulation guide) sets its own limits for mercury, cadmium and lead in batteries; REACH still applies to the other substances of a battery.
Toy safety: Directive 2009/48/EC is being replaced by Regulation (EU) 2025/2509. Annex XVII entry 51 restricts phthalates in toys and childcare articles. See the EN 71 EU toy safety guide.
Cyber Resilience Act (CRA) (see the Cyber Resilience Act guide) does not address chemistry, but a connected product carries both files.
Waste Framework Directive 2008/98/EC is the legal basis for SCIP. End of life of electronic equipment is governed by the WEEE Directive 2012/19/EU.
Every economic operator that places an article on the market should keep, per component, the Candidate List screening, the Article 33 information sent and the SCIP reference. The spilma glossary covers the abbreviations SVHC, RAC, SEAC and CoRAP.
See also
Section titled “See also”- Environmental compliance: what it asks of a product
- RoHS: restriction of hazardous substances
- PPWR: Packaging and Packaging Waste Regulation
- TSCA: US Toxic Substances Control Act
- CPSIA and ASTM F963: toy safety in the United States
- WEEE 2012/19/EU: European e-waste management framework
- DEEE in France: French version of EU WEEE
- EU Battery Regulation 2023/1542: passport, carbon
- ESPR (EU) 2024/1781: Sustainable Products Reg
Watch points
Section titled “Watch points”| Risk | Consequence | Action |
|---|---|---|
| Screening the finished product instead of each article | Missed Article 33 and SCIP duties | Keep composition data per component article |
| Missing a Candidate List update | Duty starts on listing, Article 7(2) six months later | Re-screen at each ECHA update |
| Assuming a RoHS exclusion covers Article 33 | Missed communication | RoHS carve-outs exist only in some Annex XVII entries |
| Forgetting Article 7(2) as an importer | Missing ECHA notification | Check tonnage per substance across imported articles |
| Ignoring entries with future dates | Non-compliant stock | Track entries 79, 80, 81 and 83 dates |
| Unanswered consumer requests | Breach of Article 33(2) | Set up a channel that answers within 45 days |
Sources & references
- Regulation (EC) No 1907/2006 (REACH), original text, EUR-Lex eur-lex.europa.eu/eli/reg/2006/1907/oj
- REACH consolidated version of 22 June 2026 (02006R1907-20260622), EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20260622
- Court of Justice, judgment of 10 September 2015, FCD and FMB, C-106/14, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62014CJ0106
- Directive 2008/98/EC Waste Framework (legal basis for SCIP), EUR-Lex eur-lex.europa.eu/eli/dir/2008/98/oj
- Waste Framework Directive consolidated version of 16 October 2025 (Article 9), EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0098-20251016
- ECHA, European Chemicals Agency, ECHA echa.europa.eu/
- ECHA, Candidate List of substances of very high concern, ECHA echa.europa.eu/candidate-list-table
- ECHA, SCIP database, ECHA echa.europa.eu/scip-database
- ECHA, universal PFAS restriction dossier, ECHA echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18663449b
- Candidate List update of 4 February 2026, 253 entries (secondary source, ECHA site blocks automated reads), CIRS Group www.cirs-group.com/en/chemicals/eu-reach-officially-adds-2-new-substances-of-very-high-concern-svhc-list-updated-to-253-entries
- DBDPE added to the Candidate List on 5 November 2025 (secondary source), Intertek www.intertek.com/products-retail/insight-bulletins/2025/1497-eu-reach-echa-adds-dbdpe-candidate-list-2025/
- Legislative train: revision of the REACH Regulation, European Parliament www.europarl.europa.eu/legislative-train/theme-a-new-plan-for-europe-s-sustainable-prosperity-and-competitiveness/file-revision-of-the-reach-regulation
- ECHA committees advance broad PFAS restriction under REACH (secondary source on RAC and SEAC dates), Arnold & Porter www.arnoldporter.com/en/perspectives/advisories/2026/03/echa-committees-advance-broad-pfas-restriction-under-reach
Frequently asked questions
- What is REACH and who does it apply to?
- REACH is Regulation (EC) No 1907/2006 on the registration, evaluation, authorisation and restriction of chemicals. It entered into force on 1 June 2007; registration, evaluation and authorisation applied from 1 June 2008 and Annex XVII restrictions from 1 June 2009 (Article 141). Registration falls on manufacturers and importers of a substance above one tonne per year. Producers, importers and suppliers of articles, such as electronic components and finished devices, carry the Article 7(2) notification duty, the Article 33 communication duty and the Annex XVII restrictions.
- What is the difference between REACH and RoHS?
- RoHS (Directive 2011/65/EU) restricts ten substances in homogeneous materials of electrical and electronic equipment and goes with CE marking. REACH is horizontal: it covers substances, mixtures and articles of every sector, through registration, the Candidate List of SVHC, Annex XIV authorisation and the Annex XVII restrictions. It carries no CE marking. Several Annex XVII entries exclude equipment within RoHS scope, for example the phthalate entry 51 and the lead in PVC paragraphs of entry 63.
- What does SVHC mean and what must an electronics manufacturer do?
- An SVHC is a substance that meets an Article 57 criterion and has been placed on the Candidate List under Article 59. The list held 253 entries after its 4 February 2026 update. When an article contains a listed SVHC above 0.1 % weight by weight, Article 33 requires the supplier to give the recipient enough information for safe use, at least the substance name, and to answer a consumer request free of charge within 45 days. Since judgment C-106/14, the 0.1 % is computed on each article a product is made of, not on the whole product.
- What is the SCIP database and who has to submit to it?
- SCIP is the ECHA database created under Article 9(2) of the Waste Framework Directive 2008/98/EC. Article 9(1)(i) requires any supplier of an article, as defined in Article 3(33) of REACH, to send ECHA the Article 33(1) information from 5 January 2021. The duty therefore follows the same 0.1 % per article trigger as Article 33. ECHA must give access to waste treatment operators and, on request, to consumers.
- What is the difference between Annex XIV and Annex XVII of REACH?
- Annex XIV lists substances subject to authorisation: after the sunset date, placing on the market and use are prohibited unless the Commission grants an authorisation for that use. The consolidated text of 22 June 2026 has 59 entries. Annex XVII lists restrictions, entry by entry, with numbered entries up to 83 in that version. The Candidate List has no ban attached: it triggers Articles 7(2) and 33 and SCIP, and is the pool from which Annex XIV entries are drawn.
- Is REACH being revised?
- The Commission work programme for 2025 announced a REACH revision. On 27 April 2026, the Commissioner for the environment told the European Parliament ENVI committee that the Commission had concluded not to open REACH at this point. The European Parliament legislative train lists the file as blocked by the Commission. Changes now come through amendments to the annexes, such as the Annex XVII entries added in 2024 to 2026.
- How is the universal PFAS restriction proposal progressing?
- Denmark, Germany, the Netherlands, Norway and Sweden submitted the proposal in January 2023. The ECHA risk assessment committee (RAC) released its final opinion and the socio-economic committee (SEAC) its draft opinion on 26 March 2026; the consultation on the SEAC draft closed on 25 May 2026 and the final SEAC opinion is expected by the end of 2026. Only then can the Commission propose an Annex XVII entry. A separate PFAS entry already exists for firefighting foams (entry 82).
- How does REACH interact with CE marking and other regulations?
- REACH is not a New Legislative Framework act and carries no CE marking or notified body. It applies in parallel with RoHS, the Battery Regulation (EU) 2023/1542 and the toy safety rules, and some Annex XVII entries carve out products those acts already cover. The Waste Framework Directive borrows the Article 33 duty to build SCIP. A product file therefore needs one substance map that answers each regime separately.